Executive Court Reporters (301) 565

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UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

U.S. DEPARTMENT OF ENERGY PUBLIC MEETING ON ENERGY CONSERVATION STANDARD SUPPLEMENTARY ANALYSES FOR DISTRIBUTION TRANSFORMERS

U.S. Department of Energy 1000 I ndependence A venue, SW Washington, D C 20585 Room 8E

- 089

Wed n es day
J une 20, 2 0l2

Facilitator :

J ames Raba U.S. Department of EnergyExecutive Court Reporters (301) 565

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Participants Identified:

Tim Ballo Earth j ustice 1625 Massachusetts Avenue Suite 702 Washington, DC 20036

Robert Berman Berman Economics 1915 Grand Court Vienna, VA 2218 2

Dr. Edwin Brush BBF & Associates 154 West 2 nd Street, No. 219 Boston, MA 02127

John Caskey Electrical Manufacturers Association 1300 North 17 TH Street, Suite 1752 Rosslyn, VA 22209

Greg Coulter GE Prolec 2030 Yellowstone Drive Fort Mill, SC 29707

Andrew deLaski

A ppliance S tandards A wareness P roject 16 Cohasset Street Boston, MA 02131

Chuck Foster Edison Electric Institute Foster & Jamison 410 Rosedale Court Warrenton, VA 20187

Carlos Gaytan Prolec GE International S.de R.L. de C.V. Blvd. Carlos Salinas de Gortari Km. 9.25 Apodaca, N.L. 66600 MexicoExecutive Court Reporters (301) 565

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Steve Griffith National Electric al Manufacturers Association 1300 North 1 7TH Street, Suite 1752 Rosslyn, VA 22209

Bruce Hirsch Baltimore Gas and Electric 1068 North Front Street, Room 300 Baltimore, MD 21202

Alex Hoffman

A merican P ublic P ower A ssociation 1875 Connecticut Avenue, NW, Suite 1200 Washington, DC 20009

Gerald Hodge Howard Industries , Inc. PO Box 158 8 Laurel, MS 39441

Richard Lyke AK Steel Corporation 705 Curtis Street Middletown, OH 45043

Aaron Meyers Cooper Power Systems 1900 East North Street, M/S 1CC Waukesha, WI 53188

Jerry Corkran Cooper Power Systems 1900 East North Street Waukesha, WI 53188

Steve Nadel American Council for an Energy

- Efficient Economy 529 14th Street N.W., Suite 600 Washington, DC 20045

Wes Patterson Navigant Consultant 2705 Scottsdale Lane Raleigh, NC 27613Executive Court Reporters (301) 565

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Ray Polinski

ATI Allegheny Ludlum 585 Silicon Drive Leechburg, PA 15656

Steven Rosenstock Edison Electric Institute 701 Pennsylvania Avenue , NW Washington, DC 20004

Bob Saint National Rural Electric Cooperative Association 4301 Wilson Boulevard, SS9

- 204 Arlington, VA 22203

Mahesh P. Sampat EMS International Consulting Inc. 1180 Brookview Dr ive Athens, GA 30606

Bob Smith Federal Pacific 601 Old Airport Road Bristol, VA 24201

Meili Sohl Edison Electric Institute 701 Pennsylvania Avenue, NW Washington, DC 20004

Webinar Participants (Identified) :

Alan Tr a ut Power Partners 200 Newton Bridge Road Athens, GA 30607

Alan Wilkes Wilks Consulting 1049 Valley Road Dyersburg, TN 38024

Ali Ghaforian ERMCO, Inc.Executive Court Reporters (301) 565

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1040 Scott Terrace Athens, GA 30606

Andrew Sw isher Engineering 7300 Fenwick Lane Westminster, CA 92683

Antoni o Trujillo Cooper Power Systems 1900 North Street Waukeshau, WI 53188

Bikash Basu Distribution Apparatus 7300 Fenwick Lane, Room 169 Westminster, CA 92683

Brian Kaja General Electric 7000 West Bert Kouns Industrial Loop Shreveport, LA 71129

Carl Bush PEMCO Corporation P.O. Box 1319 Bluefield, VA 24605

Charles Drexler Kentucky Association of Electric Cooperatives 4515 Bishop Lane Louisville, KY 40220

Charles Simmons Progress Energ y 1418 Mechanical Boulevard Garner, NC 27529

Craig DeRouen
ERMCO 2225 Industrial Road Dyersburg, TN 38024

Daniel Peterson Central Moloney, Inc.Executive Court Reporters (301) 565

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P.O. Box 6608 Pine Bluff, AR 71611

David Lis Northeast Energy Efficiency Partnerships 91 Hartwell Avenue Lexington, MA 02421

Makoto Shinohara Hitachi 46

- 1 Tomioka Tainai

- shi , Japan 9592608

Dave Millure Metglas Inc

. 440 Allied Drive Conway, SC 29526

Demetrios Thanasouli s National Grid 175 Hicksville, NY 11801

Do ng Kim Engineering 1 Innovation Way Pomona, CA 91768

Ebrima Cham Consolidated Edison 1601 Bronxdale Avenue Bronx, NY 10462

Eduardo Robles Engineering 4100 Rio Bravo Suite 211 El Paso, TX 79902

Edward Varnado IID Energy 333 East Barioni Boulevard Imperial, CA 92251

Eric Petersen
AK S teel Corporation 705 Curtis StreetExecutive Court Reporters (301) 565

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Middletown, OH 45053

Ishmael Leon Prolec GE Carlos Salinas de Gortari Mexico 66600

James Rakowski

ATI Allegheny Ludlum 1300 Pacific Avenue Natrona Heights, PA 15065

Jerry Allen Metglas, Inc. 440 Allied Drive Conway, SC 29526

Jerry Schoen AK Steel Corporation 705 Curtis Street Middletown, OH 45043

John Oates

LIPA 175 East Old Country Road Hicksville, NY 11801

Joseph Rempe
Tacoma Power 3628 South 35 th Street Tacoma, WA 98409

Justin Rush Westar Energy 4001 NE 14th Topeka, KS 66612

K atie Katie Co u g h lin Lawrence Berkeley National Laboratory MS 90

- 4000 Berkeley, CA 94729

Kenneth Winder Moon Lake Electric Association, Inc.Executive Court Reporters (301) 565

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800 West U.S. Highway 40 Roosevelt, UT 84066

Kevin Oehlmann Consolidated Edison 4 Irvin g Place New York City , New York 10003

Linda Wilson NYS Office of the Attorney General 120 Broadway New York, NY 10271

Paul Ryan
HMA

- Metglas 800 Grand Avenue Carlsbad, CA 92008

Paul Sturgio u Consolidated Edison 1601 Bronxdale Avenue Bronx, NY 10462

Philip Hopkinson

HV OLT , Inc. 3704 High Ridge R oa d Charlotte, NC 28270

Ray Harlow Young & Company 530 South Marengo Avenue Pasadena, CA 91101

Richard Lyke AK Steel Corporation 705 Curtis Street Middletown, OH 45043

Rob Carmichael Navigant Consulting 1900 M Street Washington, DC 20036

Robert V an Buskirk U.S. Department of EnergyExecutive Court Reporters (301) 565

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1000 Independence Avenue, SW Washington, DC 20585

Robin Roy Natural Resources Defense Council 1152 15 th Street Washington, DC 20005

Seth Blumen SRP P.O. Box 52025 Phoenix, AZ 85072

Susmitha Tarlapally

ABB 500W Highway 94 Jefferson City, MO 65109

Tamara Johnson Springfield Utility Board P.O. Box 300 Springfield, OR 97477

Tom Petrosino TRP Consulting 1917 Park Road Charlotte, NC 28203

Wilton C edeno Consolidated Edison 4 Irving Place New York, NY 10003

ConEd

Participants from DOE:

John Cymbalsky U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585

Alan Strasser U.S. Department of Energy 1000 Independence Avenue, SWExecutive Court Reporters (301) 565

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Washington, DC 20585 James Raba U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585

Participants from Navigant Consulting and Lawrence Berkeley National Laboratory :

Brian Coffey Navigant Consulting 1900 M Street Washington, DC 20036

Mike Rivest Navigant Consulting 1900 M Street Washington, DC 20036

Matt hew Nardotti Navigant Consulting 1900 M Street Washington, DC 20036

Chris Bolduc Lawrence Berkley National Laboratory 1 Cyclotron Rd

M /S 90

- 4000 Berkeley, CA 94720

Greg Rosenquist Lawrence Berkley National Laboratory 1 Cyclotron Rd

M /S 90

- 4000 Berkeley, CA 94720

Pamela Costello Navigant Consulting 1900 M Street Washington, DC 20036

Presenters:

Brian Coffey Navigant ConsultingExecutive Court Reporters (301) 565

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Chris Bolduc Lawrence Berkley National LaboratoryExecutive Court Reporters (301) 565

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AGENDA

ITEM PAGE

Welcome, Mr. Raba 8

Self

- Introductions 12

Agenda Review 1 6

Regulatory History, Mr. Coffey 18

Navigant Presentation, Mr. Coffey

Added Liquid Immersed Equipment Classes 2 0

TSLs 34

LBL Presentation, Mr. Bolduc

Scaling 38

National Level Impacts, NIA Results 95Executive Court Reporters (301) 565

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9:13 a.m. 1

P R O C E E D I N G S 2

MR. RABA: Let’s get started. Please take 3

your seats. Good morning everyone . Welcome to the 4

Department of Energy’s Public Meeting, whether 5

you’re in person or via the Webinar. This is the 6

U.S. Department of Energy’s Public Meeting about the 7

Supplementary Analysis for Liquid Immersed 8

Distribution Transformer s. T oday is Wednesday, June 9

20 th , the first day of summer, here in the Forrestal 10

Building, Washington, D.C. 11

My name is Jim Raba, Department of Energy. 12

I will be the facilitator for today. So good to see 13

you this morning. I’m glad you could make it here 14

on time for an early start in the day. We have some 15

opening remarks from our presiding officer, John 16

Cymbalsky. 17

MR. CYMBALSKY: Thanks, Jim. Welcome 18

everybody to the liquid immersed distribution 19

transformer meeting. The title is very important 20

here be cause that is the only focus of today’s 21

meeting. Today we are not here to talk about any 22

other topics relating to transformers. We have not 23

revised analysis into the final rule. This is just 24

supplementary work that we undertook based on 25

comment, and bas ed on what we talked about during 26Executive Court Reporters (301) 565

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the negotiated rulemaking back last fall . We wanted 1

to separate out some product classes and just take a 2

look at the numbers, so that is our focus today. I 3

appreciate the fact that people in the room might 4

have other thi ngs to say about transformers and they 5

submitted comments to our proposal. We are 6

currently reviewing those comments so please don’t 7

feel the need that you need to repeat comments that 8

are not pertaining to this exact topic. We’d like 9

to keep on point he re, keep the meeting focused and, 10

you know, we have several hours for this, but we’d 11

like to keep it on focus. 12

Also I’d like to help with the Webinar, I 13

think we finally figured out our technical issues, 14

and what that came to be is that we were leaving 15

m icrophones turned on when we’re not using them, and 16

so when a voice on the phone came off the speakers 17

it went into the microphone and caused feedback for 18

the people on the phone, on the Webinar. So I would 19

ask everybody, if you’re not speaking into your 20

microphone, please switch it off, including the 21

stand mics in the back. There’s an on/off switch. 22

If you come up to speak in the mics on the stands, 23

you switch it up to speak and then please when 24

you’re done, switch it off and then this way 25Executive Court Reporters (301) 565

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everyone on t he phone can hear without feedback. At 1

the last couple meetings it worked very well when we 2

all adhered to this policy. 3

With that, back to Jim, and again, thank 4

you all for coming. 5

MR. RABA: I may be repeating some of what 6

John said, but very helpful of course to keep us all 7

on the same methodology, the same process. But 8

today we’re going to focus on whether certain types 9

of liquid immersed distribution transformers that 10

are currently part of the same equipment classes 11

warrant separation, to b e separate into separate, 12

distinct equipment classes. For example, where pole 13

and pad mounted distribution transformers from the 14

same equipment class, would they be more 15

appropriately evaluated as separate equipment 16

classes? And similarly, we’ll address the 17

appropriateness of evaluating network and vault

18

based liquid immersed distribution transformers as 19

separate equipment classes. 20

I recall on February 10, 2012, Notice of 21

Proposed Rulemaking, and during the February 23 rd 22

public meeting, DOE asked for co mments and whether 23

certain types of liquid immersed distribution 24

transformers should be separate, distinct equipment 25Executive Court Reporters (301) 565

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classes. A number of interested parties submitted 1

comments to support such an approach for pole and 2

pad

- mounted liquid immersed distributi on 3

transformers. In addition, they urged DOE to 4

separate the equipment classes for network and 5

vault

- based distribution transformers with basic 6

impulse rating levels of 200 kilovolts or more. 7

And since that time, our experts at 8

Lawrence Berkeley Nationa l Laboratory, Navigant 9

Consulting have prepared a supplemental analysis of 10

trial efficiency standard levels that include life 11

cycle cost and payback period analysis for each 12

separate class of liquid immersed distribution 13

transformers. ] 14

So today’s discu ssion, as John pointed 15

out, will focus on that analysis. There’s been no 16

modifications or analysis for dry type distribution 17

transformers because of the purpose and the focus of 18

today’s public meeting. So we want to hear from 19

you, your comments, recommen dations, data, and 20

information. 21

So, we traditionally start off with 22

introductions around the room, and then followed by 23

introductions from those who are joining us via the 24

Webinar. I’m going to start to my left. Turn your 25Executive Court Reporters (301) 565

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microphone on before speaking, state your name and 1

organization. Speak loud and clear and turn your 2

microphone off when you finish speaking. 3

Self

- introductions 4

MR. LYKE: I’m Richard Lyke, I’m 5

representing AK Steel Corporation. 6

MR. BERMAN: Robert Berman, Berman 7

Economics. 8

MR. GAYTAN: I’m Carlos Gaytan, Prolec GE. 9

MR. COULTER: Greg Coulter, GE Prolec. 10

MR. POLINSKI: Ray Polinski, ATI Allegheny 11

Ludlum. 12

MR. SAINT: Bob Saint, representing the 13

National Rural Electric Cooperative Association, 14

NRECA. 15

MR. HIRSCH: Bruce Hirsch, Baltimore Gas 16

and Electric, representing the Edison Electric 17

Institute 18

. MR. ROSENSTOCK: Steve Rosenstock, Edison 19

Electric Institute. 20

MR. HODGE: Gerry Hodge from Howard 21

Industry. 22

MR. deLASKI: Andrew deLaski, Appliance 23

Standards Awareness P roject. 24

MR. CASKEY: John Caskey, National 25Executive Court Reporters (301) 565

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Electrical Manufacturers Association. 1

MR. STRASSER: Alan Strasser, Department 2

of Energy. 3

MR. CYMBALSKY: John Cymbalsky, DOE. 4

MR. SAMPAT: Mahesh Sampat, EMS 5

Consulting. 6

MR. GRIFFITH: Steve Griffith, N ational 7

Electr ical Manufacturers Association. 8

MR. BRUSH: Ned Brush, consultant to the 9

Copper Development Association. 10

MR. PATTERSON: Wes Patterson, consultant 11

for Navigant. 12

MR. FOSTER: John Foster representing 13

Edison Electric Institute. 14

MS. SOHL : Meili Sohl, representing Edison 15

Electric Institute. 16

MR. RABA: Check to see if that microphone 17

is on, please. Thank you. 18

MR. ROSENQUIST: Greg Rosenquist, Lawrence 19

Berkeley National Laboratory. 20

MR. BALLO: Tim Ballo with Earth Justice. 21

MR. RABA: In the back here. 22

MR. BOLDUC: Chris Bolduc, Lawrence 23

Berkeley National Laboratory. 24

MR. RIVEST: Mike Rivest, Navigant 25Executive Court Reporters (301) 565

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Consulting. 1

MR. COFFEY: Brian Coffey, Navigant 2

Consulting. 3

MR. NARDOTTI: Matt Nardotti, Navigant 4

Consulting. 5

MR. RABA: Over here, yes. 6

MR. MEYERS: Aaron Meyers, Cooper Power. 7

MR. RABA: Welcome. Welcome. We welcome 8

everyone now

-- now for those who are on the 9

webinar, there are a couple ways to provide 10

questions and comme nt, but first of all, if you 11

would raise your hands to introduce yourselves

. 12

Okay, nothing? Is there anybody on the phone at 13

this time? Okay. No one on the phone now. There 14

are a couple ways to do this

-- 15

PARTICIPANT: Jim, I think we have a 16

techni cal difficulty. I know there are people that 17

are on the phone that couldn’t maybe respond. 18

MR. RABA: Right. Via the phone, indicate 19

you’d like to provide a question or comment by 20

raising your hand in the “Go to Meeting” software. 21

The moderator will b e notified that your hand is 22

raised. Once called upon, say your name and 23

organization, and speak loud and clear. Does that 24

help? Also you could gain access via the “Go to 25Executive Court Reporters (301) 565

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Meeting.” Use the question window and go to meeting 1

and submit a question that wi ll be related to the 2

moderator. If you’re providing a lengthy question, 3

you’re asked by the organizer to ask your question 4

via the phone, if we can get it to work. The 5

function is best reserved for long, technical 6

issues. 7

We’re writing things down now, those who 8

can’t see the room. This again

-- those who are 9

participating on the phone via the webinar, welcome. 10

We have quite a lot of people here. I’ll go top to 11

bottom. Alan Traut , Alan Wilkes, Antonio Trujillo, 12

Carl Bush, Charles Drexler, Charles Si mmons, Daniel 13

Peterson, Dave Millure, Demetrios Thanasoulis , Do n g 14

Kim, Ebrima Cham , Eric Peterson, Ishmael Leon, 15

James Rakowski, Jerry Allen, K atie Coughlin , Kevin 16

Oehlmann , Linda Wilson, Paul Sturgio u , Phil 17

Hopkinson, Rob Carmichael, Robert Van Buskirk, Robin 18

Roy, Tom Petrosino, and Wilton C edeno . 19

Hands raised, first hand I see raised is 20

Antoni o Trujillo. The phone should work. 21

MR. TRUJILLO: I just wanted to make sure 22

that you can hear us. 23

MR. RABA: Oh, good. That’s great. Good, 24

you w ere right on cue, sir, thank you. Okay. Other 25Executive Court Reporters (301) 565

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hands raised, Linda Wilson. 1

MS. WILSON: You just asked if anyone was 2

on the phone, so I said yes. 3

MR. RABA: Thank you. Perfect. And James 4

Rakowski’s hand is raised. Are you there sir? 5

MR. RAKOWSKI: Okay. I’m just trying to 6

make sure. 7

MR. RABA: Okay. We can hear you. Thank 8

you. I think we’ve got it worked out. So okay, I 9

think we’ve solved the phone logistics. Thank you 10

very much for your patience there in webinar land. 11

It may be a good id ea, when you do speak, turn your 12

phone on, not speaking, turn your phone on mute to 13

d r own any other feedback that might get in the 14

system. 15

Agenda Review 16

So, you all received a packet of 17

information as you came in the door. I’ll refer to 18

that packet. Th ere’s an agenda. There is also a 19

copy of the proposed rulemaking, or the Notice of 20

Public Meeting for this, and also the slides for 21

today’s presentation. 22

I’ll start by briefly going over the 23

agenda. From this agenda, after this, we’ll have 24

our expert s from Lawrence Berkeley National 25Executive Court Reporters (301) 565

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Laboratory and Navigant Consulting give 1

presentations on the supplemental analysis

-- it’s 2

in your packet of information

-- after which we’ll 3

entertain comments and discussion. Somewhere in 4

here we’ll take a break around 10:30 or so this 5

morning for a coffee break. There’s lots of 6

opportunity for discussion about the trial sta ndard 7

levels, life cycle cost and payback period analysis 8

and more. 9

We’re scheduled to finish up today about 10

one o’clock, so I think, not wanting to truncate the 11

opportunity for comment and discussion, so we’ll go 12

efficiently and rapidly forward. We’ll just see how 13

long it takes for us to do this, otherwise if about 14

twelve o’clock or so, or 12:30, we still have a fair 15

piece to go, we’ll pause for l unch, return and go 16

back at it. 17

But so far, this is our agenda lineup, you 18

can see it on your screen also at home. Are there 19

any questions about the agenda, or comments? I see 20

none at this point, hear none also. Okay. 21

So, I’d ask for your consid eration. Many 22

of you are familiar with this process. Please speak 23

one at a time. You have to turn the microphone on 24

to speak. Each time, please say your name for the 25Executive Court Reporters (301) 565

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record, and I’ll be cuing individuals by name as 1

best I can so you know who’s in the q ueue. We’ll 2

also encourage any follow

- on comments. The back and 3

forth between individuals is sometimes very helpful 4

to the Department as it’s sorting through what to do 5

with all this commentary. So please keep the focus 6

here, turn you cell phones to sil ent mode if you 7

would, please. Limit sidebar conversations. If you 8

can, try to be concise, there’s a lot to be said. 9

Having read the PowerPoint slides last 10

night, a lot of content here, so let’s see if we can 11

keep it focused on the analysis today. I m ust say 12

if we’re as disciplined in the discussion today as 13

you were in introductions, then it bodes well for 14

us, I think. 15

So I’d like to proceed with the 16

presentation slides. Brian, would you start us off, 17

please. Brian Coffe y , Navigant Consulting. 18

Regulatory History 19

MR. COFFEY: Can everybody hear me okay? 20

I think some yes’s and some no’s. Yes’s? Great. 21

So good morning. Brian Coff ey with Navigant 22

Consulting. First, let’s take a quick review of the 23

rulemaking history. EPCA 2005 set standards for low 24

voltage dry type transformers at the NEMA TP1 2002 25Executive Court Reporters (301) 565

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level. In October of 2007, DOE issued a final rule 1

establishing standards for both liquid immersed and 2

medium voltage dry type transformers. DOE was sued 3

on that rule relating to issues of environmental 4

compliance, and that suit was settled. As a result 5

of that settlement agreement, compliance was 6

required in 2010 on the original schedule with 7

standards establi shed in that 2007 rule. 8

However, DOE agreed to an expedited 9

timeline to determine whether or not to amend 10

standards for liquid immersed and medium voltage dry 11

type transformers. So along those lines, DOE 12

publishes a Notice of Proposed Rulemaking in 13

Febr uary of this year, which I’m sure everybody has 14

seen, and then the final rule after that must be 15

published by October 1, 2012 according to that 16

settlement agreement. 17

So here’s a timeline of the major 18

rulemaking events. We had our first look at the 19

analy sis in 2011, and a NOPR in February of this 20

year. The final rule publishes on October 1 st with 21

compliance required in January 2016. 22

So what brings us here today? In response 23

to the NOPR, several parties submitted written 24

comments supporting new equip ment classes for liquid 25Executive Court Reporters (301) 565

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immersed distribution transformers. So this would 1

include, potentially, pole mounted transformers, 2

network and vault

- based transformers, and those with 3

BIL ratings of 200 kV . In response to that, DOE is 4

providing supplementary ana lysis

-- has provided 5

supplementary analysis with several new trial 6

standard levels and new equipment classes relating 7

to those TSLs. And this is for liquid immersed 8

transformers only. 9

The new TSLs which are lettered A through 10

D . The original TSLs had numbers and the new ones 11

have letters, just so everyone can distinguish. The 12

new ones provide separate standards for pole 13

mounted, network and vault

- based, and 200 kV BIL

14

rated transformers. 15

I want to be clear that this supplementary 16

analysis was cond ucted with the NOPR data and tools, 17

so it’s not any kind of pre

- final rule work, it’s an 18

extension of what was done before. And just to 19

reiterate, no modifications have been made to any of 20

the dry type classes, low voltage dry or medium 21

voltage dry are th e same. 22

Added L iquid

- Immersed Equipment Classes 23

So now let me take you through those 24

additional equipment classes and TSLs. There’s some 25Executive Court Reporters (301) 565

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judgment involved in dividing a covered product 1

scope into equipment classes, and DOE does it to 2

maximize energy sa vings, maintain equipment utility, 3

and minimize regulatory complexity. In this case, 4

DOE saw strong stakeholder support for new liquid 5

immersed equipment classes, including those for pole 6

mounted transformers, network and vault

- based 7

transformers, and tho se with BIL ratings of 200 kV

. 8

So let me discuss those last two first. 9

Network and vault

- based transformers are 10

generally located in underground concrete vaults in 11

dense urban areas where construction work can be 12

done only at great cost. These uni ts are generally 13

built in the stacked core configuration, where H0 is 14

really the best grade of steel that’s used. DOE 15

understands that a very large fraction of these 16

units are already being built with H0 , and so 17

manufacturers simply can’t use the next gra de up of 18

steel to avoid size increases. You know, if you’re 19

not at the top grade and you really can’t get bigger 20

or to do so would be of great cost, then you can hop 21

up to a new steel grade and it’s expensive, but 22

you’ve saved yourself the hassle of diggi ng up the 23

vault and replacing the whole thing. But if 24

everybody is already at the top grade of steel, then 25Executive Court Reporters (301) 565

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that trick can’t be played any more. So, depending 1

on how much wiggle room there is in the vault, 2

higher standards could mean very expensive vault 3

replacements that would far outweigh the benefit of 4

any energy savings obtained. 5

DOE believes that the market size by KVA 6

for network and vault transformers is more or less 7

five percent, but that’s something that DOE would 8

like comment on. 9

Moving to 200 kV BIL

- rated transformers == 10

yes, question? 11

MR. COULTER: This is Greg Coulter with GE 12

Prolec. Can we ask or make comments as you talk, or 13

are we going to wait to the end? 14

MR. COFFEY: No, as we go is great. 15

MR. COULTER: When you talk about ne twork 16

and vaults, we noticed that there was only a three

17

phase category for them. There are network and 18

vault single phase transformers, and we thought 19

there ought to be a similar single phase category. 20

MR. COFFEY: So I’ll go through the 21

equipment clas s structure. There is a single phase 22

category. 23

MR. COULTER: For network and vaults? 24

MR. COFFEY: Yes. 25Executive Court Reporters (301) 565

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MR. COULTER: We just didn’t see that in 1

the thing that came out. Okay. 2

MR. COFFEY: I’ll go through the details 3

of that in a second. But to continue with 200 kV 4

BIL

- rated transformers. So basic impulse level is a 5

measure of transformers’ resistance to very high 6

voltage transients, which would often come from , 7

say , a lightning strike. The more protection a 8

transformer has, the more difficult it is, difficult 9

and costly, to pursue higher efficiency. Although 10

in the past DOE has kept all liquid immersed BIL 11

ratings together in a single equipment class, 12

further incre ases will push the highest protection 13

levels, the highest BIL ratings up into the steep 14

portion of the cost curve, where the energy savings 15

are less justifiable. 16

There is some precedence in doing this. 17

DOE already does so with medium voltage dry type 18

transformers. And DOE believes that the market size 19

for these 200 kV BIL

- rated units is about one 20

percent by kV , but again, comment would be 21

appreciated. Yes, please. 22

MR. COULTER: This is Greg Coulter again. 23

200 BIL represents almost nothing in the m arketplace 24

for these size transformers. Maybe a quarter of one 25Executive Court Reporters (301) 565

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percent is more than generous. Maybe less than 200 1

total transformers a year might be generous. We 2

think that break is at 150 kV BIL. 200 BIL is 3

meaningless in this size transformer. You n eed

-- a 4

big change happens when we have to go to 150 BIL, 5

and we think that’s where the big changeover comes, 6

where it makes it very different for us to meet some 7

of these efficiency ratings. It’s not 200 BIL. We 8

could care less. I think the majority o f people in 9

the room would care less about it. If it was 200 10

BIL you might as well not have it. You’ve either 11

got to make it meaningful or take it out entirely. 12

MR. COFFEY: That’s helpful. Thank you. 13

Do you have a sense, offhand

-- I’m putting you on 14

the spot here

-- but do you have a sense offhand of 15

what the market size would be by KVA if the line 16

were drawn at 150? Do you have a gut instinct? 17

MR. COULTER: Yeah, my guess is it’s 18

around three to four percent. 19

MR. COFFEY: Okay. Thank you. 20

MR . deLASKI: This is Andrew deLaski from 21

the Appliance Standards Awareness Project, as a 22

follow on for Greg. So Greg, just to help us 23

understand, is there a bright line

-- do you have 24

products at 150 and products at 200? Is there a 25Executive Court Reporters (301) 565

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space in between or is that

-- you sell 150 or you 1

sell 200, but you don’t sell 175s? 2

MR. COULTER: Simple answer is you’re 3

exactly right. The breaks are 95, 125, 150, and 4

200. 5

MR. deLASKI: Okay. So there is no in

6

between ? 7

MR. COULTER: There is no in

- between. And 8

ther e’s essentially no 200, so, you know, we’re big 9

-- 150 at least you get some volume, and 200 there’s 10

essentially no volume. In a good year, going back 11

ten years ago, we might have sold 200 units as an 12

industry of 200 BIL. That was a very good year. 13

MR. deLASKI: Right. Another follow on. 14

We, in our comments, and in our response to the 15

NOPR, and I guess you’re aware, you know, we 16

suggested that the levels that were proposed by the 17

Department didn’t really merit any separation of 18

product classes for low er BIL

-- for higher BIL 19

products for poles or vaults. We thought that the 20

proposal was of such modest improvement that the 21

changes didn’t need special treatment. So I guess 22

my question for you is, at what level does it become 23

apparent to you that you wo uld

-- that it becomes 24

challenging to built a high

-- to even build a high 25Executive Court Reporters (301) 565

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BIL over 150? In the levels that have been 1

evaluated by the Department, is it at level one, 2

level two, level three? Please use efficiency level 3

because the TSLs, you know, we’ll g et all lost in 4

that. 5

MR. COULTER: There isn't an easy answer 6

to that. But what we definitely see is a major 7

shift, a major shift in the way we make product and 8

the price of product, and the ability to meet the 9

efficiency levels, when you get to the 150 BIL 10

level. Certainly, at some of these efficiency 11

levels we have talked about here, you’re out of 12

where you can really compete with a silicon steel. 13

You’ve really pushed it into an amorphous category. 14

I mean, can we make them? Yeah. We make amorphous

. 15

We do it all the time, and we can handle it. The 16

point is, you’re not competitive with silicon steel. 17

And that’s

-- that’s the criteria we were going by. 18

MR. deLASKI: Okay. For this three to 19

four percent of the market that is 150 or greater. 20

MR. COULTER: Right. 21

MR. deLASKI: Okay. Great. Thanks. 22

MR. COFFEY: So thank you, that’s helpful. 23

This is precisely what this meeting is for, is to 24

get feedback on the equipment classes, how they’re 25Executive Court Reporters (301) 565

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defined and the TSLs that accompany them. Yes, 1

plea se. 2

MR. MEYERS: Aaron Meyers, Cooper Power. 3

Andrew, to answer your question more specifically, 4

it’s less than five percent that are greater than 5

150 and above, from essentially last year’s shipment 6

data for Cooper, and for 200 kV it’s like a tenth of 7

a percent. 8

MR. deLASKI: Your numbers are pretty 9

similar to Greg’s. 10

MR. MEYERS: Supporting Greg’s comment 11

earlier, 200 kV is essentially nothing, and it’s 12

less than five percent for 150 and above. And 13

that’s on a per unit basis. 14

MR. COFFEY: Okay. Well, great. Let me 15

take you through the new equipment class structure. 16

Here you can see

-- here we’re showing how the new 17

equipment class structure relates to the old. You 18

have the old on the left. In the past, it was 19

simple. There is equipment cla ss one for single 20

phase, and equipment class two for three phase. And 21

now on the right, each of these equipment classes is 22

subdivided into the letters A, B, C, and D. One 23

thing to note is that 1A and 2A are the classes for 24

anything that doesn’t meet the definition of 25Executive Court Reporters (301) 565

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something else, so it’s a catch

- all. It’s not

-- in 1

the analysis that was published on line, we 2

initially had gotten into the habit of referring to 3

them as pad

- mounted transformers, but we realize 4

that there could be other units here and the re that 5

maybe aren’t thought of as traditional pad

- mount 6

units, per se. So this is sort of the

-- 1A and 2A 7

is the default class. 8

1B and 2B are specifically for pole 9

mounted units, overhead poles. And 1C and 2C are 10

for network and vaults, one and three phase. And 11

then 1D and 2D are for the 200 kV units. 12

MR. ROSENSTOCK: Steve Rosenstock, EEI. 13

But based on the testimony, you might

-- these could 14

change, correct? 15

MR. COFFEY: They could. 16

MR. ROSENSTOCK: Thank you. 17

MR. COFFEY: That’s what today is for, is 18

to receive feedback on that. 19

MR. RABA: Brian, we have a hand raised 20

from Alan Wilkes. Alan, go ahead, please. 21

MR. WILKES: I would like to be unm uted on 22

my internet. 23

MR. RABA: You’re on, sir. 24

MR. WILKES: Yes, I’d like to be unm u ted. 25Executive Court Reporters (301) 565

- 0064 34

MR. RABA: You’re on. 1

MR. WILKES: Thank you. 2

MR. CYMBALSKY : No, no. Only if he has a 3

question will he be unmated. Do you have a 4

question? 5

MR. RABA: Do you have a question, Mr. 6

Wilkes? 7

MR. WILKES: No, not at this present time. 8

MR. CYMBALSKY : So, Mr. Wilkes, you will 9

be unm u ted only if you have a question, otherwise, 10

all the phones will be muted until there is a 11

question. So if you have a question, raise your 12

hand and we’ll unmute you, okay? 13

MR. WILKES: Thank you. 14

MR. COFFEY: So now let’s take a look at 15

what we have for representative units. Two tables. 16

Left hand table is single phase, and the right hand, 17

three. Equipment classes 1B and 2A, so that’s the 18

right column in the left table and the left column 19

in the right table , those each have two design lines 20

which makes the scaling simple, because one can 21

simply choose ELs for each design line 22

independently, and then fit the line in logarithmic 23

space for a smooth, straightforward, and self

24

consistent standard. 25Executive Court Reporters (301) 565

- 0064 35

Equipment cla ss 1A, that’s on the far 1

left, only has a single representative unit, so 2

there are a few more decisions to be made there, 3

which I’ll talk through. And then finally, 4

equipment class 2B. So these are the three

- phase 5

pole mounts, and it’s DOE’s understandin g that the 6

vast majority of three

- phase pole mounted 7

transformers are constructed by triplexing three 8

single phase cores. So, really it’s like three 9

single phase units in one housing. And if that’s 10

true, then it follows that the transformers should 11

be as efficient as each of its constituent cores, 12

only at three times the power level. 13

And so DOE, in equipment class 2B, DOE 14

shows here that the equipment class 2B standards 15

begin scaling from the single phase pole mounts in 16

1B, where there are two design li nes and a little 17

bit more robust analysis. Yes, please. 18

MR. ROSENSTOCK: Steve Rosenstock, Edison 19

Electric Institute. In terms of the three

- phase 20

pole mount, 750 to 2500, it says scaled

-- it says 21

scaled from this slide, and then the following 22

slide. I guess one

-- and again, I appreciate this 23

information, but it seems like at least in the 24

information that we’ve received so far we have no 25Executive Court Reporters (301) 565

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way of knowing kind of where that falls in terms of 1

the various ELs. So we’re kind of

-- it’s kind of 2

opaque. It says it’s scaled, but we have no idea, 3

does that really kind of corresp ond to an EL1, or an 4

EL2 or an EL3, or what numbers are we talking about 5

there? I couldn’t find any information about where 6

those numbers actually lie in the information that 7

was sent out by DOE. It just says scaled, and then 8

there’s an overall analysis, but I couldn’t

-- I 9

couldn’t find it, maybe I wasn’t looking in the 10

right place. Where do those numbers fall, I say in 11

terms of the ELs? 12

MR. COFFEY: Sure. I have some tables 13

that I’m going to present that may answer that 14

question, but I can say, just for your own 15

intuition, the three phase poles are going to have 16

the same efficiency standard as the one phase pole 17

with the same

-- I’m sorry, one

- third the KVA 18

rating. So a single ph ase pole at 100 KVA, would 19

receive the same standard as a three phase pole at 20

300 KVA, and that’s because the way that they’re 21

most commonly built is to just put three single 22

phase 100 KVA cores in one housing. But we’ll look 23

at the TSL charts. 24

MR. RABA : Brian, one more thing too, we 25Executive Court Reporters (301) 565

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have a hand raised from Mr. Antonio Trujillo on the 1

phone. Mr. Trujillo, you’re live, go ahead please. 2

MR. TRUJILLO: My questions is, just the 3

example that you described, is that only for poles? 4

Is it going to be diffe rent for pads? 5

MR. COFFEY: That’s right. 6

MR. TRUJILLO: Okay. Thank you. 7

MR. CASKEY: John Caskey, NEMA. And 8

looking at the original NOPR from February 10 th I 9

think it is, and in there you had various design 10

lines, like, for example, design line one was liquid 11

immersed single phase rectangular tank, ten to 167 12

KVA range, and then you have a representative sample 13

there. Do those DLs relate at all to the DLs i n the 14

most recent additional analysis? 15

MR. COFFEY: They do. That’s a good 16

point. So the ELs are the same for all the design 17

lines. Again, this is an extension of the NOPR 18

analysis, and so all of the ELs and TSLs that 19

existed in the NOPR exist in this analysis, they 20

haven’t changed. The only thing that DOE has done 21

is added new TSLs using the existing ELs and gave 22

them letters A through D. 23

MR. CASKEY: I’m not sure I asked the 24

question correctly. What I’m looking up here where 25Executive Court Reporters (301) 565

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you have the DL1 for 1A which goes from 10 KVA up to 1

833 KVA, how does that definition of that DL1 relate 2

to the definition of DL1 that’s in the NOPR 3

published February 10 th

. 4

MR. COFFEY: So the design line itself is 5

exactly the same. What’s different is how it’s 6

being scal ed to derive standards for equipment 7

classes. And previous ly , that table that you’re 8

looking at on the left, all three of those rep units 9

were in a single class because we didn’t have poles 10

and pads and networks and vaults. But now, we’ve 11

got two design lines in the 1B equipment class for 12

pole mounts, and only one rep unit in the 1A class 13

for everything else. And so as you’ll see, I’ll 14

describe that you need to make some decisions about 15

how you’re going to scale that unit. How can we use 16

the information for all three design lines to 17

construct an appropriate standard. 18

MR. CASKEY: Okay. So just to make sure I 19

understand. So basically the DLs from the February 20

10 th NOPR and the DLs in this additional analysis are 21

the same, and the definition of the ELs and the 22

efficiency levels are the same but the scaling may 23

throw them off in some areas? 24

MR. COFFEY: That’s right. 25Executive Court Reporters (301) 565

- 0064 39

MR. CASKEY: Okay. Thanks. 1

Trial Standard Levels 2

MR. COFFEY: So now let’s talk about TSLs. 3

DOE has added four new trial standard l evels to 4

cover these equipment classes, and they’re lettered 5

A through D. And just to refresh everybody’s 6

memory, TSLs are sets of standards that DOE chooses 7

from when proposing a standard and when actually 8

setting one. And what it does is, for each 9

equi pment class, chooses ELs, packages them up, and 10

then that becomes a TSL. So some of the TSLs, you 11

can see in the chart here, which ELs go with which 12

equipment class and design line. And so there will 13

be some overlap, right, so a single EL can exist in 14

mu ltiple TSLs. Yes, please. 15

MR. ROSENSTOCK: Steve Rosenstock, Edison 16

Electric Institute. In the Notice of Proposed 17

Rulemaking there were seven TS L s and now there’s 18

four more, so basically since it is a final rule 19

stage, basically all 11 are in play, cor rect? 20

MR. COFFEY: That's correct. 21

MR. ROSENSTOCK: And there could be other 22

TSLs if you do any other analysis, correct? 23

MR. COFFEY: There’s

-- that’s 24

theoretically possible, but

-- 25Executive Court Reporters (301) 565

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MR. ROSENSTOCK: We could suggest 1

alternative TSLs in our comments, correct? 2

MR. COFFEY: Sure, yes. 3

MR. ROSENSTOCK: Would they be considered? 4

MR. COFFEY: Yes. 5

MR. ROSENSTOCK: Thank you. 6

MR. deLASKI: As a follow on to that

-- 7

MR. RABA: Andrew deLaski. 8

MR. deLASKI: Thank you. My recollection, 9

and I think the Department’s been pretty clear in 10

both this NOPR and other NOPRs for other products 11

that the TSLs are options that are considered. They 12

are at the level of the analyses, but as we saw with 13

the transformer rule in 2007, they sometimes can 14

d efine a rule that might be in between those levels, 15

so that is a

-- the levels are, depending on the 16

input from stakeholders in large part, and how the 17

analysis comes out

-- so that’s my recollection of 18

how things work. Brian’s nodding so I think that 19

was

-- 20

MR. COFFEY: It’s a fair summary, thank 21

you. 22

MR. ROSENSTOCK: And again, as another 23

summary

-- Steve Rosenstock, EEI

-- there were 24

levels in the 2007 rule, I’ll say levels one through 25Executive Court Reporters (301) 565

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five, I think one through five, one through six, and 1

when you di d the final rule, you kind of mixed and 2

matched based on the one phase, three phase and it 3

turned out to be levels two, three, or four, four 4

and a half, depending on the type of transformer and 5

whether it was pad or pole mounted, single or three 6

phase. So , you know, you mixed and matched last 7

time, so it’s kind of

-- again, just for a 8

reference, that’s what happened last time, that you 9

mixed and matched between different levels, 10

basically. 11

MR. deLASKI: And that four and a half was 12

an in

- between level. Thank you. 13

MR. COFFEY: Okay. And so of course to 14

make a cluttered slide even more cluttered here is, 15

for each design line and TSL, the corresponding EL 16

efficiency value, losses in watts, and then implied 17

percentage loss reduction from the baseline. So in 18

the rightmost column you see sort of what that block 19

corresponds to, ELs, efficiencies, losses, and then 20

percentage reductions depending on how you find it 21

most intuitive to think about. 22

MR. RABA: Steve Rosenstock, go ahead 23

please. 24

MR. ROSENSTOCK: Steve Rosenstock, EEI. 25Executive Court Reporters (301) 565

- 0064 42

On the losses, is that the total losses at the 1

specified testing level? I guess it was

-- liquid 2

filled I guess it was 50 percent

-- is that the 3

estimated losses at the 50 percent loading? 4

MR. COFFEY: That’s right. 5

MR. ROSEN STOCK: Thank you. 6

MR. BERMAN: Robert Berman, Berman 7

Economics. Just a request, at the end of the 8

presentation, can you make these types of tables 9

available on the web at much higher resolution so 10

those of us with glasses

-- 11

MR. RABA: Yes, we will d o that, 12

definitely. 13

PARTICIPANT: Speak into the mic please. 14

MR. BERMAN: So those of us with glasses 15

can read them. 16

MR. COFFEY: Yes, absolutely. Thank you. 17

We’ll try to make sure that everything is legible 18

and in the event that something isn’t, I can 19

absolutely provide a higher res table. 20

(Comment off mic rophone ) 21

MR. COFFEY: So there’s a lot of 22

information here, but I think it should be in your 23

handouts if you’d like to spend some more time with 24

it, and next we’ll discuss how these ELs are sc aled 25Executive Court Reporters (301) 565

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from each design line to become a fully fledged set 1

of standards. 2

Scaling 3

Just to review, trial standard levels or 4

TSLs include efficiency levels only for DOE’s 5

representative units. To derive standards for the 6

rest of the scope of coverage, DOE does what is 7

called scaling analysis. Most of our equipment 8

classes have at least two representative units for 9

which, as I noted, a standard is constructed by 10

fitting a straight line along a logarithmic space. 11

So you pick an EL for each one and two points give 12

you a line, and then that’s a standard. 13

But in the cases of equipment cl asses 14

having only a single point, there are a couple of 15

options. Just to recap. DOE uses two scaling 16

points for classes 1B, 2A and 2B. Those each have 17

two points, so it’s easy to derive a line. Class 18

1A, which is the single phase catch all class, has 19

o nly one scaling point, and that’s at design line 20

one. And so now we’ll look at where the different 21

options for deriving a standard for that equipment 22

class. 23

PARTICIPANT: Brian, just to clarify, the 24

handouts have it

-- 25Executive Court Reporters (301) 565

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MR. COFFEY: The handouts, I sh ould say, I 1

think 1A and 2A may be switched. 2

PARTICIPANT: Okay. So the presentation 3

is correct, but the handout has a typo, just to be 4

clear. 5

MR. COFFEY: Thank you. And a copy of 6

this presentation will be posted on DOE’s website, 7

so don’t worry abo ut making all the annotations or 8

anything like that. This will be sent out in its 9

current form. 10

I think all of this is best discussed 11

using an example. What we’re looking at here is a 12

plot of loss versus KVA, and they’re both 13

logarithmic for equipment classes 1A and 1B. Again, 14

so that’s single phase catch

- all and single phase 15

pole mounted. We have pole mount design lines at 16

both 25 and 500 KVA, that’s for 1B, and a pad mount 17

design line at 50 KVA for 1A. At each of those KVAs 18

you’ll see a string of d ots for each efficiency 19

level, or EL, and because they’re a little bit 20

packed together, we also have zoom

- ins at the end of 21

each line in the corners. So it looks like there 22

are kind of three plots on here, but actually the 23

top left corner and the bottom r ight corner are just 24

zoomed in versions of the ELs, so you can more 25Executive Court Reporters (301) 565

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accurately see where the crossing happens. 1

So how does the scaling work? Well, if we 2

choose ELs at 25 and 500 KVA for equipment class 1B, 3

that gives us a straight line. We can divide t he 4

line for equipment class 1A, so that’s the 50 KVA 5

class by taking an EL at 50 KVA for that design line 6

and assuming similar physics, or a similar slope. 7

If we assume that losses grow with KVA at the same 8

rate, we get a line parallel to the first, that’ s 9

the blue line. So again, because this is a loss 10

plot , lower is more efficient. Fewer losses mean s a 11

more efficient transformer. 12

So this is just TSL B which is an example, 13

and we can see that it gives sort of a high standard 14

at 500 KVA, maybe, just an eyeball test, maybe it’s 15

EL

- 2.5, so that’s one outcome of this, right. And 16

so now let’s look at, well, if you found that would 17

be high, what would be another possibility? 18

So now we’re looking at the same plot, 19

again equipment classes 1A and 1B, TSL B s till, and 20

the red line is identical to what we just saw, it’s 21

identical here. It runs through the same

-- but the 22

blue line that you can see, instead of being 23

parallel, is converging with the red line at the end 24

of DOE’s scope of coverage. So at 833 KVA, these 25Executive Court Reporters (301) 565

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two lines meet. So it’s a little bit less stringent 1

at the higher KVAs, you can see it’s running through 2

maybe that orange circle which is about 1.5, so it’s 3

comparatively less stringent at the higher KVAs, but 4

then if you look down at the lower KV As, it’s gotten 5

more stringent. And DOE’s understanding is that in 6

this particular market segment, there are very, very 7

few sales at the high KVAs. The single phase KVAs 8

are really a very, very

-- you know, let’s say 250 9

and above, I think are a pretty s mall portion of the 10

market. 11

So for purposes of this analysis and this 12

discussion, we’ve shown all of our tables using the 13

parallel scaling technique. 14

MR. RABA: Go ahead Steve. 15

MR. ROSENSTOCK: Steve Rosenstock, EEI. 16

Just trying to interpret the scaling. It looks like 17

you’re trying to have the same delta in terms of 18

loss reductions, again at 50 percent loading with 19

your scaling, is that correct? You’re attempting to 20

do that for all of the equipment classes? You’re 21

trying to do parallel scales i n terms of possible 22

ranges of ELs? 23

MR. COFFEY: So I’m not sure I understand 24

your question. 25Executive Court Reporters (301) 565

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MR. ROSENSTOCK: Well, you show the 1

parallel lines and then you show the converging 2

ones, in terms of some of the new, I’ll say the new 3

TSLs or maybe the old on es, were you trying to keep 4

looking at parallel numbers for all of the ELs, that 5

you tried to prevent converging? 6

MR. COFFEY: Not necessarily prevent. 7

These are just two options. You know, I framed the 8

-- what is the task at hand here? And the task a t 9

hand is to create a standard for an equipment class 10

that has only a single point. So if you choose an 11

El for that point, you’ve defined a standard right 12

there, but then you have a line running through it 13

and the slope of that line can vary. And what th at 14

does is makes it comparatively more or less 15

stringent at higher or lower KVAs. 16

So what I’m trying to overview here is the 17

different ways that one might go about doing this, 18

and one of the options is to assume similar physics 19

as were present in the p ole mounted transformers, 20

and you have a parallel line, and another option is 21

to have those two standards converge as you go up in 22

KVA. 23

MR. ROSENSTOCK: Okay. Steve Rosenstock, 24

EEI. So the Y axis scale

-- it’s a regular scale, 25Executive Court Reporters (301) 565

- 0064 48

it’s not logarithmic, it’ s a regular scaling on the 1

Y axis side. It says, you know, it goes from minus 2

2.3 to positive point three, and it says loss

-- I 3

guess I’m a little confused by that. I’m not sure 4

what that Y axis really means at the different KVAs. 5

One way to read it is , you know, some of the things 6

actually increase losses, if it’s above zero? 7

MR. COFFEY: So the axis is in the log of 8

loss, so both axes are actually logarithmic, and 9

that’s the way that you get a straight line. 10

MR. ROSENSTOCK: That’s a logarithmic 11

scale on the left? 12

MR. COFFEY: Both of them. So the numbers 13

are actually the result of the log themselves. So 14

not a lot of intuitive meaning, but just to, I 15

guess, have it there. The

-- yes. 16

MR. RIVEST: So I struggled with this 17

graph myself quite a bit. 18

MR. RABA: Mike, this is the first time. 19

MR. RIVEST: Oh, and I fully appreciate 20

that. You may recall from previous conversations 21

and from the previous rulemaking that when we 22

analyze a specific KVA rating, like 25 KVA, and we 23

all debate and t alk about if EL1 is the right one, 24

or EL2, or EL3. But we never had LCC results at 25Executive Court Reporters (301) 565

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larger KVA ratings versus smaller KVA ratings. So 1

what we’re trying to do is say, okay, what we’ve 2

done a 25 KVA. If we extend it to the other KVA 3

ratings to get the equi valent stringency, which for 4

a manufacturer might mean the same steel, or the 5

same construction, typical construction. So what we 6

did in the last rulemaking is we used the .75 7

scaling rule, and the .75 scaling rule looks like a 8

straight line with a slope of .75 in this one viewed 9

this way. 10

The problem we got into in the last 11

rulemaking is that we picked an EL for one KVA 12

rating, another EL for another KVA rating and then 13

had to fit a line through it and try to come up with 14

a smooth curve. So here we’r e defining the 15

standards right away to be a straight line so we 16

don’t get this mismatch at the end. And the way 17

we’re doing that is we’re defining

-- we’ve got EL1 18

for the 500 KVA. We have EL1 or point five, 19

whatever the TSLs defines for the 25 KVA, and we’re 20

right away drawing a straight line through, and 21

we’re saying that’s what the standard would look 22

like. And it comes very close to .75, but it’s not 23

always .75. Sometimes it goes as high as .79 and 24

we’ve seen .76. 25Executive Court Reporters (301) 565

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So where we have those two dots at 25 and 1

500, we draw the line and we know we’ve got a nice 2

uniform standard. Where we only have that one dot, 3

we need to extend that dot to the other KVA ratings. 4

We could do like in the last rule and just use .75, 5

and that’s certainly one option. An other option is 6

to take the same slope as for the other product 7

class, the poles having the same slope as the pads 8

is what we’re talking about. And that would give us 9

.76, which is pretty close. And that’s all this is. 10

It’s not very intuitive, but the end 11

result, I think Brian is going to show, is that it 12

creates a nice smooth curve. When we look at this 13

standard now as efficiency versus KVA. 14

MR. COFFEY: So yes, I can pull that up

. 15

This is equipment class 1A, so this is just one of 16

those li nes, and now we’ve

-- 17

MR. RIVEST: So

-- Mike Rivest again. If 18

you look at the light blue, which is the lowest line 19

here, and now we’ve got on one axis efficiency, and 20

on the other axis, KVA. So higher is more 21

efficient. Our baseline is that light blu e. And by 22

looking at that you would make the observation that 23

the current standard seems to be more stringent on 24

the low KVA ratings than it is on the high

. I think 25Executive Court Reporters (301) 565

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that’s what we’re hearing also, that we heard during 1

these workshops. So our proposed sta ndard, TSL1, 2

you’ll notice that, compared to the baseline, it can 3

be a significant improvement in efficiency or it can 4

be a minimal, depending on the area between those 5

two lines. 6

And you’ll notice that TSL A and TSL 1

-- 7

this is for pads, I imagine, so TSL A is more 8

stringent than the proposed level for pads. TSL B 9

is more stringent than TSL A, et cetera. If you 10

look at this for the product class for poles now, 11

you’ll see that TSL A is equal in stringency to what 12

has already been proposed. So TSL A as far as poles 13

is concerned, is the same as the proposal, because 14

those lines are on top of each other. 15

MR. RIVEST: Very close. 16

MR. COFFEY: Very close. So although 17

earlier in the table you saw one, zero, one for TSL 18

1, and 1.5, one for TSL A, that’ s actually a gross 19

simplification of what that TSL looks like because 20

in the previous instance we had to fit a line 21

through three curves

-- through three points rather 22

than two, so there was like an averaging there. We 23

were a little higher, a little less than one i n some 24

cases, a little higher than zero in other KVA 25Executive Court Reporters (301) 565

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ratings, because we couldn’t have done a smooth 1

standard by having a zero, one, zero. 2

MR. RABA: Question over there. Go ahead. 3

MR. CASKEY: Yeah, John Caskey, NEMA. If 4

you can go back to the other slide for just a 5

second, just to make sure

-- one more earlier. 6

Okay. So on this X axis it looks like it’s KVA, and 7

it’s starting at 25, and you said that’s log, so 8

what is the right hand end of that axis? 9

MR. COFFEY: (off mic rophone ` ) ...

... [the 10

limit of DOE’s] scope of coverage ... 11

MR. CASKEY: Okay. 12

MR. COFFEY: If you didn’t hear that, the 13

farthest right for which we have ELs is 500 KVA, 14

that’s our design line 3 unit. The scope of 15

coverage extends all the way to 833 for single 16

phase

. 17

MR. CASKEY: Okay. Then on the Y axis is 18

the loss. Are there units that go with those 19

numbers? 20

MR. COFFEY: So it’s the logarithm of 21

watts, you could say. Logarithm of power. 22

MR. CASKEY: Okay. 23

MR. RIVEST: Mike Rivest again. What 24

Brian

-- the issue that we’re trying to get your 25Executive Court Reporters (301) 565

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feedback on that Brian’s been discussing is that we 1

need to go with our blue line through this dot. And 2

we want to have a straight line go through that dot. 3

If we

-- and this is a point

-- we can go parallel; 4

we ca n pivot upwards or downwards, but it’s a zero 5

net gain if you will in terms of the overall 6

standard. Now if we pivot up like this, then we’re 7

making this more stringent. And the thought is that 8

the impact is really down here, for the poles. So 9

it’s more important that we get this close as 10

possible to getting through this dot at EL point 11

five? Is that what

-- we’re depending on the 12

standard

-- so it’s more important to get this dot 13

right, go through this dot and get this dot right , 14

than to go through thi s dot and get this dot. 15

MR. RABA: Greg. 16

MR. COULTER: This is Greg Coulter with GE 17

Prolec. This is kind of a key issue in this point. 18

As I used to have a professor say, one point is a 19

dot, two points is a straight line, three points is 20

a curve. S o you’re trying to take one point and 21

essentially all you have

-- even when you say you 22

have two points there, you really only have one 23

point

-- so you’re trying to make it work. I think 24

I’ve been clear in my comments before. It isn’t 25Executive Court Reporters (301) 565

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.75. The scaling f actor is not .75. It’s only 1

close across short distances

-- it’s only close 2

across short distances of KVA. The point is, as 3

manufacturers, our construction changes. We use a 4

different construction for a 25 KVA than we do for a 5

50, and we don’t build any 500s, so I never cared 6

what you did at that point anyway. But when you get 7

up to 167, where you do have volume, from ten to 8

167, we did care. But we have different 9

construction. Our low KVAs are constructed 10

completely different, strip versus wire

-- I don’t 11

want to go into all the differences with competitors 12

sitting in the room, but, you know, that’s a simple 13

one, and I think most people do that. So, this kind 14

of becomes important. 15

It’s less important when the efficiencies 16

aren’t so tough, but as we ’re getting close to where 17

any of us can do things, and it’s now becoming very 18

important on this particular point. It is always 19

easier to do these efficiencies a little bit more at 20

higher KVAs. KVA just tends to be more efficient 21

and that’s why it’s on that curve. It’s the slope 22

of the curve that makes a big difference. So even 23

the difference between a converging and a straight 24

line makes a big difference at this point. I don’t 25Executive Court Reporters (301) 565

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believe it’s that important to get a straight line 1

through 25 and 50. You r 25 is a pole, your 50 is a 2

pad. There are different points. And so it’s kind 3

of important to pick a point, and then I don’t know 4

how else you can do it . It’s too late to come with 5

more design lines, so you’ve got to use some kind of 6

scaling, but you’v e got to be a little bit 7

conservative in the scaling because of where we are. 8

And at 25 KVA and at 50 KVA, which is the heart of 9

the volume, you can scale off of it, but you’ve got 10

to get those points pretty close to right and scale. 11

I’m more on a conver ging side than the straight line 12

side. If I understand the converging

-- I mean this 13

is the first time I’ve seen it, but it looks to me 14

like that has a little more generous

-- it’s a 15

little more generous at the low KVAs. I’m wrong? 16

You’re shaking your h ead. I misread that chart? 17

MR. COFFEY: Let me

-- I think you are for 18

converging if converging means converging at low 19

levels as opposed to what we have here is converging 20

at high KVAs. So you’re for converging, but not our 21

-- a different kind of conve rging. So of these two, 22

you’re for the parallel, but you would prefer that 23

we consider converging at low KVA. 24

MR. COULTER: Where all the volume is, 25Executive Court Reporters (301) 565

- 0064 56

yes. 1

MR. COFFEY: But of course, if we have 2

total convergence, then we haven’t separated pads 3

from pol es. So the question is at what KVA would we 4

converge, if it was on the small side. Is it 25, is 5

it ten? 6

MR. COULTER: Well, first, it may not be 7

the same slope. You have a slope through those 8

KVAs, but it’s a different slope when you go up, 9

which is truly what happens, by the way. This is 10

not

-- so .75 just doesn’t work across the

-- 11

MR. COFFEY: So what’s important to get is 12

the range between what KVA and what KVA. Where’s 13

the

-- where’s 80 percent of the volume right now? 14

MR. COULTER: KVA 50 and below. 15

MR. COFFEY: Fifty and below, but not 16

zero, not one KVA> 17

MR. COULTER: Ten. 18

MR. COFFEY: Ten

-- 19

MR. COULTER: Tens, 15s and 25s is 20

probably

-- on a pole line, that’s going to be 80 21

percent of your volume. Tens, 15s and 25s. On pad 22

lin e, now, it’s going to be

-- 23

MR. RABA: Would you like to make a 24

comment

-- 25Executive Court Reporters (301) 565

- 0064 57

MR. COULTER: That 500 KVA point has no 1

meaning. It’s not even very good. The 500 KVA is 2

not very good. But my point is, we never cared 3

because we don’t make 500 KVAs

-- 4

PARTICIPANT: Some people do. 5

MR. COULTER: But some people do and some 6

people buy them. But they don’t buy many. The 7

point is, get the low points

-- 8

MR. COFFEY: I see what you’re saying. 9

MR. RABA: Steve. 10

MR. ROSENSTOCK: Steve Rosenstock, EEI

. 11

Just as a follow up, there are customers that buy 12

the 500 KVAs. I’m a little concerned about, well, 13

put it high, who cares? Well, still the customers 14

care because they’re the ones who are going to be 15

paying and it will be totally uneconomical for them

. 16

MR. COULTER: Steve, that was not my 17

point. My point is it’s not as important as getting 18

the low ones right, that’s it. 19

MR. ROSENSTOCK: Steve Rosenstock, EEI. I 20

appreciate that but it could be very important to 21

those people who buy them, if they’r e facing huge up 22

front costs for minimal efficiency gains. And if 23

you look forward to TSL 1B, yeah that one right 24

there, just a quick one

-- this is for the pole 25Executive Court Reporters (301) 565

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mount and under TSL 1, doesn’t TSL 1 equal the base 1

for that one? But you show it as a diffe rent value, 2

so I got a little confused when I was looking at 3

that one. 4

MR. COFFEY: TSL zero is the base. TSL 1 5

is the proposed level. 6

MR. ROSENSTOCK: TSL 1 is base. 7

MR. COFFEY: Excuse me? 8

MR. ROSENSTOCK: For pole mount. 9

(comments off mic roph one ) 10

MR. ROSENSTOCK: I’m looking at the chart 11

here, design line two, yes. And

-- 12

MR. COFFEY: I’m sorry. I think what 13

you’re remembering, Steve, is in the NOPR proposal, 14

the nominal proposal for design line 2 was EL

- 0

. 15

MR. ROSENSTOCK: Right. 16

MR. COFFEY: But because of the scaling 17

Mike mentioned before, there were three points in 18

that single equipment class, and so to derive a 19

standard, you know, you can’t hit three points with 20

a single line unless you happen to be really lucky 21

with the points . So what wound up happening is this 22

curve ended up being roughly EL point five for 23

design line two, roughly EL point four for design 24

line one, and roughly EL

- 1.1 for design line three. 25Executive Court Reporters (301) 565

- 0064 59

Because to run through each of the points would have 1

created this ph ysically inconsistent disjoint 2

standard that wouldn’t have made sense. So with the 3

three points in one class, the best fit line was 4

really the best that DOE could do. 5

MR. ROSENSTOCK: Steve Rosenstock, EEI. I 6

respect that and I understand what they’re doing, 7

but there are many other standards where there’s, 8

quote, “disjointed curves,” just based on analysis 9

of the market, analysis of the economics, analysis 10

of everything that’s in there. I understand. 11

MR. RIVEST : I think the difference here 12

Steve is here we were getting reversals in 13

direction. So a curve

-- it’s okay if it’s on a 14

line if it’s a curve where it’s, you know, but if it 15

looks like a camel’s back, a two humped camel is 16

what we were getting. 17

MR. ROSENSTOCK: Steve Rosenstock, EEI. 18

There are other efficiency standards where I believe 19

you get very interesting results where there is high 20

efficiency gains for some products and lower 21

efficiency gains for other products, and it would 22

not be a smooth curve. I haven’t seen them. I 23

haven’t seen the logarithmic curves, but just based 24

on other

-- just from the results of other standards 25Executive Court Reporters (301) 565

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for other products, you know, it’s, you know,

-- 1

especially the ones with multiple product classes, 2

I’ve seen situations where

-- 3

MR. RIVEST: So this is the s ame product 4

class. It would be as if we took a water heater 5

standard, which is an equation by gallons, and then 6

we had reversals in the stringency. We would say 7

the 40 gallon is one level and then you go down to 8

50 and then back up to 60. That’s just no t

-- 9

MR. ROSENSTOCK: But in that case

-- well, 10

Steve Rosenstock, EEI

-- the water heater curve it’s 11

a few percent up to 55 gallons and then it’s 120 12

percent for over 55 gallons on the electric side

-- 13

MR. RIVEST: But it doesn’t do this. 14

MR. ROSEN STOCK: Okay, so it does this and 15

then this. It still might not be a smooth curve 16

like

-- 17

MR. RIVEST: I wish I hadn’t brought up 18

water heaters. 19

MR. RABA: Okay. We have a hand raised 20

from Aaron Meyers, please. 21

MR. MEYERS: Aaron Meyers, Cooper Pow er. 22

I do appreciate the effort to smooth the curve 23

because we feel that it does represent more reality, 24

but all of the analysis that we’ve done so far has 25Executive Court Reporters (301) 565

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been using the previous scaling factor. So we 1

really haven’t assessed what the impact will be when 2

you raise the efficiency. For instance, for 1500 3

KVAs for three phase, you see 2B, that’s a pretty 4

substantial increase in efficiency, and I don’t know 5

how or if that’s reflected in the economic analysis. 6

MR. COFFEY: It should be reflected since 7

that’s one of the design lines, right, five. 8

MR. MEYERS: Yes. 9

MR. COFFEY: So five is the three phase 10

pad at 1500 KVA. 11

MR. MEYERS: That’s a significant 12

increase in efficiency. 13

MR. COFFEY: We have later in this 14

presentation, the actual

-- we’re showin g 15

graphically here what

- how the different TSLs 16

relate. We also have in tabular form the actual 17

numbers for each KVA. The efficiency values 18

themselves. 19

MR. RABA: In the back, please step to the 20

microphone. Please, your name. 21

MR. PATTERSON: Wes Pa tterson. Brian, go 22

back to that chart. Yeah, if I remember right, 23

design line five is a 1500 KVA, three phase, which 24

is those dots on the 1500 scale. I mean you have 25Executive Court Reporters (301) 565

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actual design lines on those, it’s not 1

extrapolation. 2

MR. COFFEY: That’s right, so i t would be 3

on this equipment class 2A analysis. Because it’s a 4

pad mount. 5

MR. PATTERSON: Thank you for that 6

clarification. 7

MR. RABA: Greg. 8

MR. COULTER: This is Greg Coulter. 9

Here’s another case where there comes a major change 10

in design. 500 K VA and below are pretty much free

11

form for three phase pads. You go above there, you 12

have to meet the 5.75 percent impedance, which puts 13

a major restriction on what we can do, and that’s 14

one of the reasons why we always thought there was a 15

major shift in the efficiencies when you get to 16

that. You know, meeting that impedance forces us to 17

put, I’ll call it blank space in the design, but 18

we’ve got to add space between the coil just to 19

drive the impedance up to meet standards, which is 20

space is not available to make these things more 21

efficient. Matter of fact, by standards they almost 22

become less efficient at high KVAs. It’s almost a 23

force of the 5.75 set impedance requirement. 24

MR. RABA: Wes, you’re up. 25Executive Court Reporters (301) 565

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MR. PATTERSON: Wes Patterson again. 1

Greg, on th is chart, the two design lines, one’s a 2

150, the other one is a 1500. So the entire 3

analysis of those dots is done on a physical design 4

which should accommodate this change in the 5

impedance. In those dots that are on those curves. 6

Those two curves repre sent the situation that you’re 7

describing. 8

MR. COULTER: Well, I’m not sure I agree 9

with that, Wes, because, you know, you would only 10

have two points on a curve. 11

MR. PATTERSON: We only have

-- 12

MR. COULTER: You have 150 and you have 13

1500. And every thing else is a curve fit. 14

MR. PATTERSON: And everything else is 15

trying to make some kind of fit. 16

MR. COULTER: And all I’m saying is, I 17

don’t think the 1500 is the same curve as the 150 18

because of this impedance issue. 19

MR. PATTERSON: It may not be . It may not 20

be, but then neither is the curve for 500. 21

MR. COULTER: That was the point I was 22

making earlier. 23

MR. PATTERSON: So if we look at the 24

existing standard, which is the baseline, as a 25Executive Court Reporters (301) 565

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result of how the existing standard was written, you 1

can see that hook that took place right there

-- 2

it’s what, 700 KVA or something. 3

MR. COULTER: It happens to be 500

-- 4

between 500 and 750. 5

MR. PATTERSON: Right, it was 500. 6

MR. COULTER: Because there was a major 7

design shift between 500 and 750. Th at’s why

-- 8

that’s the reason we always thought it was there, 9

made perfect sense. But now it’s being taken out 10

because looks like you’re trying to fit a curve 11

between all those points that aren’t the same 12

points. Here you truly have a major

-- 13

MR. PATT ERSON: The end result was that 14

the 500 efficiency was the same efficiency as the 15

750. 16

MR. COULTER: Yes. Yes. 17

MR. PATTERSON: Okay. But that

-- in some 18

cases, naturally, that is not the case. And not 19

across all manufacturers is that the case. 20

MR . COULTER: Well, we didn’t say it was 21

perfect. We just said it had more sense to it than 22

it does not. 23

MR. PATTERSON: But not across all 24

manufacturers. 25Executive Court Reporters (301) 565

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MR. COULTER: We have other manufacturers 1

in the room. Let them speak. 2

MR. RABA: We had three hands left to 3

right, go ahead please. 4

MR. POLINSKI: Ray Polinski, ATI 5

Allegheny. Just a comment, feeding on what Greg 6

says. Why would we change the scaling that 7

practically has worked. It’s proven, it’s 8

practical. It’s how it’s been done. And to 9

ar bitrarily change it

-- 10

MR. RIVEST: Mike Rivest. This is nothing 11

arbitrary here, okay. This was proposed

-- we got 12

comments on this, there is nothing arbitrary. We’re 13

not in this situation here, look at TSL 1 and TSL A, 14

and they’re the same, so

-- 15

M R. RABA: Do you have follow on, Ray? 16

MR. POLINSKI: Again, I’ m n ot a 17

transformer engineer so I’ll stand back and let the 18

transformer engineers speak, but what I heard Greg 19

say is just that in practice he feels that the 20

existing scaling, although it’s no t smooth, and that 21

may cause some people to have heartburn, it is, in 22

fact, it works. And so why in the world we would 23

change that. Mike you can explain. 24

MR. RABA: We saw Steve and then Andrew 25Executive Court Reporters (301) 565

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after that. 1

MR. ROSENSTOCK: Steve Rosenstock, EEI. 2

Loo king at all these curves, there’s some sort of 3

inflection point, whether it’s at 100 KVA or at 500 4

KVA, it appears to be

-- if I’m doing the bottom 5

notes right, it’s 100, 250, 500, is that

-- or is 6

that 333? I’m not sure exactly where they, you 7

know, it j ust goes from 100 to 1000, so I don’t 8

know where the vertical lines are, but just looking 9

at these, there’s no perfect curves that they have 10

now, but I think part of the reason was when DOE did 11

their last analysis was that they were matching the 12

single ph ase to the three phase efficiencies for 13

different transformers as a way to lower 14

manufacturing costs, as I recall. That was a way to 15

assist them, so you didn’t get the perfect curves, 16

but if it lowered the cost of higher efficiency 17

units, it’s kind of a w in

- win situation. 18

So, I’m not personally, you know, I know 19

we’re going to get the economics later, if standards 20

come up where it’s not a perfectly smooth curve, 21

that might be okay because that’s where the 22

economics are better for both the manufacturers and 23

the steel makers as well as the utilities, just 24

because you raise

-- if you raise it too high and it 25Executive Court Reporters (301) 565

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just distorts the market, and the prices skyrocket, 1

and then it’s not economical. 2

MR. RIVEST: Let’s think about what we’re 3

talking about here. We have a dot at 1500, which is 4

already EL1. That one’s not going anywhere. That’s 5

where it is. We have one at 150, which is at EL1, 6

that’s not going anywhere. So we’re talking about 7

creating a standard across from that 150 dot to that 8

1500 dot. We have it now, which is a straight line 9

fit in log

- log space. Okay. It creates this 10

smooth, function, one seen as efficiency times KVA. 11

What is it I’m hearing that you

-- what

-- we can do 12

a .75 scale across both of those and then we have a 13

discontinuity, and we end up with something like 14

that. 15

Now, that’s not going to lower the 16

standard necessarily. That’s going to make it

-- 17

probably make the 150 more stringent because

-- and 18

make the 15

-- I don’t know, I can’t anticipate. 19

But I don’t think the area unde r is going to really 20

change. 21

MR. RABA: Andrew. 22

MR. deLASKI: Andrew deLaski, Appliance 23

Standards Awareness Project. So just to be clear, 24

Brian, the levels, TSL1 you show on your graph here, 25Executive Court Reporters (301) 565

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these are levels that were proposed. People have 1

commented on these levels. 2

MR. COFFEY: That’s right. 3

MR. deLASKI: People have taken positions 4

on this. This has been pretty clearly noticed and 5

comment. This is not something new. 6

MR. COFFEY: No, exactly. 7

MR. deLASKI: So you guys have been doing 8

this n ow, as you said, you’ve been doing this for 9

quite a while. This isn’t new. The thing I wanted 10

to ask Greg, just to follow on to your comment about 11

-- I don’t understand, again, some of the 12

engineering constraints you’re describing, which is 13

that you add blank space

-- I know you’re describing 14

it in simple terms so people like me, and I 15

appreciate that, and that

-- but why does that make 16

it harder to be efficient? 17

MR. COULTER: In simple terms, we have to 18

make

-- the way we make stuff more efficient is w e 19

try to put it in more compact space, that’s the best 20

way you can do it. If you take out insulation, take 21

out blank space in the design, you can get the 22

winding in the core smaller. Here, we are forced to 23

put space in between the winding and the core ju st 24

to force impedance into the design. So we’re not 25Executive Court Reporters (301) 565

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able to fill that space up with winding. It’s more 1

compact, so we’re essentially adding losses, mostly 2

winding losses to the design. 3

You know, how big it is, I don’t know. 4

But it’s certainly a design change. It’s one of 5

those reasons why the .75 scaling factor doesn’t 6

work across, especially three phase pads. It’s 7

probably the most prime example I could give. It 8

works better for all the 750 KVA and above to be at 9

that, but for the 599 KVA and below , on a .75 10

scaling factor, but it doesn’t scale across the 11

whole curve. 12

If I look at that line, what you’re really 13

seeing is the lower KVAs are really moving up, 14

they’re having to be more efficient versus what they 15

used to be. That’s essentially what it ’s showing. 16

You start getting where the heart

-- where the meat 17

of the KVA is for three phase, it’s actually not as 18

big a change. It’s a little bit arguing against 19

what we might like. But the point is, I don’t think 20

-- I think there’s a point where the curves are

-- 21

the curves ought to have a slightly different shape. 22

In other words, a discontinuance in the curve. It 23

was there before. I think this one here is an 24

obvious place for it

-- it ought to be there. Now 25Executive Court Reporters (301) 565

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how big an issue that is on total losse s, I don’t 1

know, in total, I don’t know. 2

You know, in all our analysis, you know, 3

if this was there and it was in all the data we saw 4

back in February, we missed it. We were probably 5

just looking, ourselves, at the 150 and the 1500 and 6

that was it, and making all our analysis off of 7

those changes, versus all the KVAs in between. We 8

didn’t pick up that this had changed like this. 9

MR. RABA: Wes Patterson. 10

MR. PATTERSON: The first thing I want to 11

point out is that the

-- what they show with the 12

orang e dot, TSL1, that was in the NOPR in February, 13

that was in the proposal in the NOPR in February. 14

What this chart is showing is that with the new 15

equipment classes for poles, there is no change 16

between the February NOPR and today on that chart. 17

So the TSL A and the TSL1 are identical lines. 18

That’s what that chart is showing. 19

Now, coming back to the discussion about 20

was the NOPR in February correct or incorrect? The 21

assumption, Greg, that you’re making is that because 22

I’ve got to go to five percent impe dance, I have to 23

add space in the high

- low in order to jack the 24

impedance. But I can also modify the turns to jack 25Executive Court Reporters (301) 565

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the impedance, and not add any space whatsoever. 1

MR. COULTER: (comment off mic rophone ) 2

MR. PATTERSON: But the efficiency balance 3

can s till be maintained and follow that .75 slope. 4

In an optimization system, yes it can. I can 5

balance those two elements at any time. So it 6

doesn’t really change the physical relation. This 7

is a characteristic of a manufacturing practice, not 8

a physics of the design of the transformer. I can 9

change the turns ratio and still accomplish that 10

curve. 11

MR. RIVEST: In any case, Greg

-- Mike 12

Rivest

-- we’re here to get your comments and to the 13

extent that you can document and maybe if we had 14

even market data t hat shows on the high end, not the 15

baseline, because all the baselines are going to be 16

hovering on that blue line anyway, but if there was 17

some empirical way that we can justify another 18

scaling, that’s why we’re here. 19

MR. RABA: Carlos. 20

MR. GAYTAN: Carlos Gaytan, Prolec GE. 21

One comment about the equipment classes 1B and 2B 22

which are for pole mounts, is really with a KVA 23

score

-- according to the IEEE standards, the pole 24

mount transformers have a limit of up to 500 KVA for 25Executive Court Reporters (301) 565

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both single ph ase and three phase, and there might 1

be a confusion when we interpret the tables and 2

these charts for, especially for equipment class 2B 3

for three phase, because beyond

-- even at the 500 4

KVA level, probably the majority of the pole mounted 5

transformers ar e not mounted on a pole, but rather 6

on a platform above the ground level. But above 500 7

KVA, we consider them to be distribution substation 8

transformers, and there might be a confusion whether 9

those probably which have a singular construction 10

with pole mo unted transformers that are mounted on 11

the floor level, if they should be considered as 12

part of that equipment class, or because they are 13

within that KVA range, or if they have to be in 14

equipment classes 1A and 2A. That’s my comment. 15

MR. COFFEY: Thank you. 16

MR. RABA: Additional comments? Good 17

exchange so far, very lively. Go ahead, Brian. 18

MR. COFFEY: So we show the graphical 19

representation of what’s going on, which is 20

intuitive, to see certain trends. We also have some 21

tables for each TSL. This is TSL A, we’ve got all 22

four equipment classes, TSL B, TSL C, TSL D. So I 23

can linger on one of these if someone would like to 24

make a point, but otherwise they’ll be in your 25Executive Court Reporters (301) 565

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handouts to be reviewed at your leisure. And if 1

there aren’t any questions, I wi ll invite up Chris 2

Bolduc to talk about some of the economic results. 3

MR. RABA: Before we do that, Steve you 4

had something? 5

MR. ROSENSTOCK: Steve Rosenstock, EEI. 6

Just trying to look over all of the tables, and just 7

in terms of the scaling, I’m just trying to

-- you 8

said the, on this equipment class 2B scaling, just 9

double checking

-- they’re scaled with the 1B at the 10

higher KVA levels, correct? 11

MR. COFFEY: Higher KVA? What do you mean 12

by that? 13

MR. ROSENSTOCK: Well, equipment class 2B 14

is the three phase pole above a certain KVA level, 15

correct? I’m looking at the representative unit. 16

MR. COFFEY: 2B is for all three phase 17

units. 18

MR. ROSENSTOCK: All three phase pole 19

mounts, okay. 20

MR. COFFEY: And so the way that we’ve 21

done the scaling i s to give 2B the efficiency 22

standard of the 1B product of one

- third the KVA. 23

So, for example, if you look at a 50 KVA in 1B, it’s 24

99.11 at TSL B, that’s the page I’m on right now, so 25Executive Court Reporters (301) 565

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the 150 for the three phase has that same efficiency 1

value. 2

MR. ROSENS TOCK: Thank you. I hadn’t seen 3

the numbers before, so I just wanted to verify that, 4

thank you. 5

MR. RABA: Any additional comments on 6

Brian’s presentation? Thank you very much. This is 7

a good time to take a break. We’ve got a lot of 8

content yet to go ahead on the economic analysis, so 9

we’re going to take a break at this time. 10

Looking ahead at the rest of the day, I 11

think we’re pretty much on schedule, so if we took a 12

break now we return here at say, quarter to 11 by 13

that clock. Those of you who are not familiar with 14

the Forrestal Building, you need to wear your 15

visitor’s badge up high and visible ... 16

(Whereupon, at 10:30 a.m., the meeting was 17

recessed for a 23 minute period, and reconvened at 18

10:53 a.m.) 19

MR. RABA: This afternoon

-- late this 20

morning

-- we’ll begin with Chris Bolduc, Navigant 21

Consulting, who will be doing the economic analyses, 22

and we’ve received the photocopies of your business 23

cards you turned in. Did everybody get one? If you 24

didn’t I can give t hem to you here right now, or 25Executive Court Reporters (301) 565

- 0064 75

Brenda’s got them at the front desk. Pass them 1

along, please. So if you haven’t given Brenda your 2

business card, the Department keeps track of who’s 3

here so they can keep you informed later on. 4

A couple folks have joined u s in the 5

course of the meeting. Would you care to introduce 6

yourselves. 7

MR. NADEL: Steve Nadel, ACEEE. 8

MR. RABA: Thank you, Steve. Anybody else 9

join us more recently? Okay. Great. Let’s 10

continue. Start now again, resume, with Chris 11

Bolduc. 12

Eco nomic Analysis 13

MR. BOLDUC: Good morning, my name is 14

Chris Bolduc from Lawrence Berkeley National Lab. 15

I’m here to present the economic analysis. So I’d 16

like to start by saying that for the economic 17

results that were presented in the documents that 18

we re sent out, and in today’s presentation, we did 19

our utmost to use the same spreadsheet tools that 20

were shared for the NOPR analysis. What we can say 21

is that in the LCC spreadsheets we added a custom 22

efficiency field for the NOPR during the reg neg 23

sessi ons, which we exercised to analyze the new ELs. 24

The only exception in this case is for design line 3 25Executive Court Reporters (301) 565

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which we’ve cast for today and what we’re talking 1

about is a pole mounted transformer, and so we added 2

the pole replacement algorithms or methodology that 3

was used in design line 2 to design line 3, and I’ll 4

talk about that in more detail when we get there. 5

Again, the new

-- with the NIA we used

-- 6

we just remixed the TSLs and the NIA to produce the 7

impact results. 8

So, it’s a bit of a convention for these 9

slides I’m about to show, is that we have the 10

proposed rule in green and any new analysis 11

highlighted in orange. Here we have design line 1 12

which we’re casting as a single phase, 50 KVA, for 13

lack of a better term, a pad mount or other 14

transformer. You can see tha t the new EL at 1.5 15

follows the trend that we would expect it to

. 16

There’s really

-- there’s really nothing new to see 17

here. I’d be happy to take your questions if 18

anybody has anything to ask. Ray. 19

MR. POLINSKI: Ray Polinski, ATI Allegh eny 20

Ludlum. One thing, Chris, if it’s somewhere in the 21

report, if you can just direct me to where the 22

data’s at, but again, as we get to the 1.5 level, 23

what percentage of the transformers

-- how much are 24

amorphous and what percentage of them, you know, ar e 25Executive Court Reporters (301) 565

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M3 transformers? The question is the availability, 1

how much amorphous is used versus M3 at the 1.5 2

level? 3

MR. BOLDUC: Okay. I hear you. I don’t 4

have the exact numbers in front of me, but I do have 5

the larger steel components for these results. And 6

in this case for design line 1, this is 49 percent 7

SA1 and it’s 46 percent M2

-- was the mix that 8

produced these results. 9

MR. POLINSKI: Ray Polinski, ATI 10

Allegheny. Thanks, Chris. And the tonnage or 11

weight that you have, do you have any

-- one thing I 12

think that’s been communicated here repeatedly is 13

that, you know, M2

-- M3, very readily available; M2 14

much more limited availability from a supply 15

standpoint. 16

MR. BOLDUC: So your question is do I have 17

for the meeting today, a projection of steel ton nage 18

that would be required to meet the standard? 19

MR. POLINSKI: I think I’ve seen those in 20

past reports, you know, in the past analyses, hey we 21

need 250,000 tons or so many pounds, and that just, 22

you know, the question is, is there the available 23

capacit y today or potential in 2016, to meet the 24

standard, the materials available to meet the 25Executive Court Reporters (301) 565

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standard? That’s always been my understanding from 1

day one of the committee meeting was, hey, we want 2

to make sure we’ve got standards in which we have 3

adequate materi al supply to promote a robust 4

competition and to ensure that we can supply and 5

make the standard. So that was my question. 6

MR. BOLDUC: Thanks, Ray. Regrettably, 7

no, we do not have projections of the volume of 8

steel that would be required to meet each of the new 9

ELs today. Moving on

-- 10

MR. POLINSKI: One last question. That’s 11

something you would have before you would propose a 12

standard? 13

MR. BOLDUC: That would be part of the 14

final rule package, 15

PARTICIPANT: Greg Coulter wants to go on 16

the recor d

-- that was a no. 17

MR. RABA: Aaron. 18

MR. BOLDUC: Yes. 19

MR. MEYERS: Aaron Meyers, Cooper Power 20

Systems. This is really the crux of the issue here, 21

is, you know, you can look at these numbers and 22

appreciate the work that went into the economic 23

analy sis, but without robust competition between M3 24

and amorphous, I mean you’re putting all your eggs 25Executive Court Reporters (301) 565

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in one basket, and we felt that that was probably 1

the driving factor behind the original Notice of 2

Proposed Rulemaking, and all the new trial standard 3

levels that we’re evaluating here, essentially are 4

considering an amorphous only world. And we don’t 5

believe that that’s the direction, the right 6

direction for the country to move in, much less for 7

manufacturers of transformers or core steel. 8

MR. BOLDUC: If I may rebut, Aaron. At 9

the end, there’s some summary slides and the new 10

TSLs are not 100 percent amorphous for all the new 11

TSLs. 12

MR. RABA: Jerry, then Andrew. 13

MR. CORKRAN: Back when we had our last 14

meeting and we ended up at EL

- 1, the reason we wen t 15

along with that was to try to end the process 16

because that was the highest that we, as 17

manufacturers, could make using M3 core steel. And 18

we try to make higher loss levels, we’re not 19

competitive with amorphous, so you’re saying 100 20

percent amorphous

-- the DOE data agrees with that

- 21

- anything over one, your own data, says 100 percent 22

amorphous, want to go back and look at your studies. 23

And so now when you’re talking about these higher 24

levels it’s kind of

-- it’s kind of like we’re 25Executive Court Reporters (301) 565

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starting over and I’d really hate to see it. I 1

thought we had an agreement and now looks like we 2

don’t. 3

MR. CYMBALSKY: John Cymbalsky, DOE. So, 4

an agreement, I’m not

-- the only agreement that the 5

R eg N eg committee produced was not relating to this 6

topic at all. And this is additional analysis. We 7

didn’t have 1.5 analyzed in the NOPR. That’s what 8

this is for, so you’re seeing new numbers and I 9

don’t think you can draw the conclusion you just 10

drew, because this was never shown before. You 11

haven’t seen this, so if we can go through the deck 12

and we can see what shakes out here. Thank you. 13

MR. RABA: Question from Dave Millure on 14

the phone. Then to you Andrew. David, you’re live. 15

Go ahead. 16

MR. MILLURE: Thank you. Dave Millure of 17

Metglas. I believe to say 100 amor phous at EL

- 1.5 18

is not at all accurate. We are talking about things 19

that are not the subject of this meeting, first of 20

all, but there are some major manufacturers that 21

will tell you that silicon steel and amorphous are 22

competitive at 1.5. So I suggest we just move on. 23

MR. RABA: Andrew, thank you for your 24

patience. Go ahead. This is Jim. Thanks, David. 25Executive Court Reporters (301) 565

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MR. deLASKI: I want to come back to a 1

point that you made, Chris, a few minutes ago. Can 2

you tell me again what the percent

-- what the steel 3

mix is at EL

- 1 on this slide? 4

MR. BOLDUC: EL

- 1, one moment please. 5

MR. deLASKI: I think you just said it, 6

but I’m not sure I caught it. 7

MR. BOLDUC: At EL

- 1 it’s 88 percent M3. 8

At EL

- 1.5, the LCC picks the lowest first cost 9

units, and from that sampl e it’s 49 percent 10

amorphous, 46 percent M2. 11

MR. RABA: Bob Saint. 12

MR. SAINT: This is Bob Saint from NRECA 13

and I’m still wondering if this whole analysis is 14

credible, because it doesn’t appear that you have 15

addressed the power cost issues that we’ve ra ised 16

before. And I was wondering if you were going to 17

address those later, or

-- 18

MR. BOLDUC: Bob, that was a comment 19

directed at the NOPR analysis. The presentation 20

today is an extension of the NOPR analysis. We did 21

receive your comment. That’s all I can say, we 22

received your comment, thank you. 23

MR. RABA: Again, let’s keep the focus of 24

the meeting. Please. Aaron, back to you, then 25Executive Court Reporters (301) 565

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Steve. 1

MR. MEYERS: Aaron Meyers, Cooper Power. 2

Again, I appreciate the analysis that was generated. 3

When we talked before we were concerned about the 4

crossover point between amorphous and M3, and we 5

went back and used our actual design program to 6

identify the crossover point, and for

-- we looked 7

at 25 KVA poles, 50 KVA poles, 25 KVA pads, 50 KVA 8

pads, 500 KVA p ads, 1500 KVA pad, and in no case was 9

it at the EL

- 1. The closest to EL

- 0.5. So I’ll 10

make that point and would like to go on the record 11

by saying that is the point of maximum 12

competitiveness from Cooper’s point of view, and the 13

slope of the grain

- oriente d curve is so steep that 14

once you go beyond that it very quickly becomes one 15

material choice only, and that’s amorphous. 16

MR. deLASKI: Just to follow up on that, 17

this is Andrew deLaski, if I could. Again, as we 18

discussed last fall, of course, that analy sis is 19

very sensitive to the relative price of the 20

materials, that’s what drives it, right. So,

-- 21

MR. MEYERS: That’s why I said it was 22

steep. That’s why I said the steepness of the 23

grain

- oriented curve runs away from the amorphous 24

curve very quickly, and so I wouldn’t want to go 25Executive Court Reporters (301) 565

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beyond that point because the M3 curve can’t 1

compete. 2

MR. RABA: First Steve Rosenstock, then 3

Robert Berman. 4

MR. ROSENSTOCK: Steve Rosenstock, EEI. 5

Again, getting back to the economic analysis, the 6

spreadsheet that was s ent out with the announcement, 7

it was

-- 8

MR. BOLDUC: Design line 3? 9

MR. ROSENSTOCK:

-- design line 3, yes, 10

and I was looking at a couple of tabs. I just want 11

to kind of ask about the numbers in there. First of 12

all, on the summary tab, it had infor mation about 13

average no load energy price, average load loss 14

energy price, average no load demand price, average 15

load loss demand price. And as I was

-- 16

MR. BOLDUC: Steve, again, this sounds 17

like a continuation of Bob Saint’s comment, which is 18

regard t o the no load energy price, is that right? 19

MR. ROSENSTOCK: Well, and a load energy 20

price that was used for this A, B, C, and D. 21

Weren’t these used for the A, B, C, and D? 22

MR. BOLDUC: They were. They were also 23

used in the NOPR, as I stated before. T his is the 24

s ame economic analysis. The only change for design 25Executive Court Reporters (301) 565

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line 3 was the inclusion of the pole replacement 1

algorithm or methodology

. 2

MR. ROSENSTOCK: Okay. And just a very 3

quick follow up. In the spreadsheet there was a tab 4

for sensitivity analysi s, and that tab was blank. 5

MR. BOLDUC: That’s right. That’s not 6

implemented yet. 7

MR. ROSENSTOCK: Will part of the 8

sensitivity be using the power prices that were 9

suggested by the utilities? 10

MR. BOLDUC: Can’t say. 11

MR. ROSENSTOCK: Thank you. 12

M R. CYMBALSKY: Again, that’s not part of 13

the meeting, Steve. 14

MR. RABA: Robert Berman, you’re up first. 15

MR. BERMAN: Robert Berman, Berman 16

Economics. One point that we should keep in mind in 17

terms of reading the results and crossover points 18

and so f orth, is if we expect

-- if we find at the 19

crossover, whatever the crossover point is, we would 20

expect to find 50 percent sales of one material and 21

50 percent sales of the other. That is, the 22

likelihood is 50:50 at that point. If we find that 23

at EL

- 0, fo r example, that that’s the crossover 24

point and we find that amorphous

-- that’s the 25Executive Court Reporters (301) 565

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crossover point that would suggest that 50 percent 1

market share for amorphous and that doesn’t exist. 2

There’s no data that suggests that that’s the case, 3

so you’ve got som e real data, then, to check your 4

crossover point calculations. 5

MR. RABA: Thank you. The other Steve. 6

MR. NADEL: Steve Nadel, ACEEE. A process 7

suggestion. Looks like everybody’s ready to pounce, 8

making points before we even barely begun this 9

discus sion. Perhaps we should let them present the 10

results and then everybody can pounce based on this 11

presentation, rather than based on any preconceived 12

notion before the presentation. 13

MR. CYMBALSKY: I’d prefer a different 14

word than pounce. But that’s jus t me. 15

MR. RABA: Jerry, no pouncing, but go 16

ahead. 17

MR. CORKRAN: I’ll pounce

-- regarding Mr. 18

Berman’s crossover points, I totally disagree on the 19

50 percent, and based on

-- it’s not based on any 20

designs, I don’t believe we have the ability to make 21

tr ansformer designs. But anyhow, my other point you 22

guys are considering M2, but M2 is only available in 23

a very limited quantity along with making M3. So 24

you should not be considering M2. When you get past 25Executive Court Reporters (301) 565

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M3, you’re leaving the market behind. You guys w ere 1

thinking M2, but M2 is, I think, something like 18 2

percent of the market is all it can be M2, so it 3

just doesn’t come out any different than that. The 4

steel manufacturers, I’m hopeful, will confirm that. 5

PARTICIPANT: Yeah. 6

MR. CORKRAN: So I thin k it’s very 7

important you guys do not lock in on saying well, 8

we’ve got M2 available, because it’s not available. 9

MR. LYKE: This is Rick Lyke, AK Steel. I 10

can confirm that we can’t make 100 percent M2. We 11

have to have a good market for M3 because the 12

targets in terms of chemistry and processing are 13

much tighter to make that product. 14

PARTICIPANT: But we’ve got to jump on 15

that. 16

MR. LYKE: So we need, yeah, M3 is the 17

volume product we can put out. We can put out some 18

M2, but 15 to 20 percent, probably. 19

MR. RABA: Okay. Thank you. Go ahead, 20

Chris, we’ll proceed. Again, good comments back, 21

good exchange. Go ahead, please. 22

MR. BOLDUC: Thank you. Right now on this 23

slide here we have a DL

- 2 where we analyzed a t half 24

an EL. I think the o ne thing I’d like to point out 25Executive Court Reporters (301) 565

- 0064 87

here in the appendix 1A, the median LCC savings was 1

-- this was presented as minus $533 dollars. That 2

was incorrect. We have it corrected here as a 3

positive $20 dollars, in bold. 4

Overall, what we do see on this design 5

l ine, which is you can see in the actual

-- the 6

payback period is illustrated very well, is that 7

when we move from below EL

- 1 to El

- 1 and higher, we 8

see a full transition that the LCC is picking 9

amorphous steel from the design sample. In this 10

case, the mix of steel that is used to produce these 11

results was 90 percent M2. 12

MR. RABA: Ray. 13

PARTICIPANT: At 0.5. 14

MR. BOLDUC: At 0.5, that’s correct. 15

MR. POLINSKI: Ray Polinski, ATI 16

Allegheny. Again, I started off by saying early on 17

that I disagreed th e way

-- the same comment as was 18

made before. We can’t make 100 percent M2, either 19

M2 is a very select processing parameter, its 20

chemistry, et cetera. And so the one comment here 21

for design line 2 was my understanding when the 22

initial NOPR came out, just again, when the initial 23

NOPR came out, there was a scaling issue and so EL

- 0 24

was for design line 2, but it ended up being like 25Executive Court Reporters (301) 565

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point four because of scaling issues. We not only 1

made separate categories, and the fact that at point 2

five you need 90 percent M2, again, I just go on the 3

record that design line 2 should be a true EL

- 0. At 4

zero. There’s no need to scale it to point four 5

because we’re not scaling, we’ve mixed up the 6

categories, so I just want to make that comment. 7

MR. BOLDUC : Okay. I’d like to counter 8

just a little bit here. So I just really want to be 9

clear that the steel percentages that I’m stating 10

are the steels that

-- they’re from the units that 11

were selected from the design sample by the LCC 12

spreadsheet. It’s just an artifact of the modeling. 13

MR. deLASKI: Andrew deLaski, if I can 14

follow on, because

-- so Ray, I guess I’m a little 15

confused because at the NOPR hearing you supported 16

the Department’s proposal, and the proposal’s levels 17

were clear, they’re laid out in the NOPR, and it was 18

essentially the levels

-- it was the levels that you 19

read, as you said, they had the scale because of the 20

pads and the poles were in a single class. And so 21

at the time, when you read that analysis, did you 22

think that it would require you to have 90 pe rcent 23

M2 for the poles? 24

MR. POLINSKI: Ray Polinski, ATI 25Executive Court Reporters (301) 565

- 0064 89

Allegheny. Andrew, yeah, we had the initial meeting 1

and generally, as I say, the NOPR was 1, 0, 1, 1, 1. 2

There was some issues with one

-- we were in favor, 3

you know, of maybe going a little high er on the 4

pads, but by the comment period which was due by 5

April 10 th I believe, we were very clear in the 6

comment period that, you know, for design line 2, 7

the point four level or point five level would 8

really make the M3 not competitive. And so that’s 9

t he facts. I mean, you can look at the crossover 10

charts that were prepared for the DOE by Navigant 11

and you can see where M3’s slightly not competitive 12

at the base case for design line 2

. That’s the 13

facts. 14

MR. deLASKI : That’s the Navigant 15

analysis, and it’s one analysis. I think we’ve 16

heard each manufacturer has run analysis, and we’ve 17

heard different information from manufacturers over 18

the course of the docket and the negotiation. I 19

mean this point of the crossover , we’ve been talking 20

about it for a long time now, and I don’t think that 21

the Navigant analysis is dispositive. And I think 22

that the reaction of the manufacturers to the NOPR 23

indicates to us that it’s not. Because folks 24

thought, the manufacturers and the steel industry, 25Executive Court Reporters (301) 565

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supported the NOPR. So to me that’s a pretty strong 1

indication that the NOPR didn’t put us into all M2 2

frame of design lines. 3

MR. POLINSKI: Ray Polinski, ATI 4

Allegheny. Again, Andrew, to your point, as I say, 5

we realize that there’s n o perfect analysis, but the 6

analysis we were told we were supposed to comment on 7

was the analysis that was presented by the DOE. And 8

to your point, if the NEMA members, they feel that 9

they can survive at a design line 2 average EL

- 0, 10

which is really a poi nt four, well, we respect that, 11

they make the transformers. But the data that we 12

have, based on the data that we’re making these 13

decisions on, it’s

-- the crossover point is where 14

M3 is not competitive at zero, that’s just the 15

facts. 16

MR. deLASKI: And w hat do people use to 17

build baseline transformers today by and large? 18

MR. POLINSKI: You’re asking me? 19

MR. deLASKI: Yeah. 20

MR. POLINSKI: You’d have to ask the 21

transformer guys, I think it’s

-- 22

MR. deLASKI: Wes, what are you guys using 23

for baseline transformers? 24

MR. PATTERSON: M3. 25Executive Court Reporters (301) 565

- 0064 91

MR. deLASKI: And it’s competitive

-- 1

(comments off mic) 2

MR. deLASKI: People are voting M3 as the 3

baseline transformer, that’s what’s being used 4

today. If it’s not competitive, again, it speaks to 5

the flaws in t he Navigant analysis, that it’s not 6

truly telling us where this crossover is, and I 7

think that’s the point that we want to make is that 8

if the crossover continues to be a problem with the 9

crossover, it’s not the purpose of the meeting 10

today, John, so I’ll keep it brief, but we continue 11

to have this problem. It is a critical issue

-- it 12

is the critical issue in the docket, absolutely it’s 13

the critical issue in the docket, where we have the 14

competition so we have robust competition amongst 15

suppliers. We’ve all agreed on this from, I think, 16

our first meeting. 17

MR. CYMBALSKY: I agree, so maybe I can 18

just step in and say the Department understands 19

that, appreciates that, gets that, and we will look 20

very, very strongly at that. So maybe we can just

- 21

- we all get it, let’s just

-- 22

MR. POLINSKI: Can I make one last 23

comment, John, please. You know, because Andrew 24

made a lot of comments directly at me, and the only 25Executive Court Reporters (301) 565

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thing is

-- and I would ask the transformer guys to 1

comment. I’m not a transformer engineer as I said 2

before, and I just don’t know, to your point, if M3 3

is used at today’s baseline standards, and meets the 4

standard, but is that due to availability of 5

amorphous? If there was more amorphous available, 6

would it be still a lower cost transformer? I d on’t 7

know the answer to that question. You say M3 is 8

being used, but is it being used at a slight cost 9

disadvantage? That’s what the charts suggest. 10

MR. RABA: Aaron. 11

MR. MEYERS: Aaron Meyers, Cooper Power 12

Systems. A couple points here. First of a ll, 13

regarding the 50 percent breakdown that Mr. Berman 14

brought up, I mean, a little bit of that has to do 15

with manufacturing capacity. So if a manufacturer 16

has the capacity to build twenty times more 17

conventional steel transformers than amorphous, 18

obviousl y there’s not going to be a 50:50 split. 19

And that also somewhat addresses the point as to 20

what transformer manufacturers are building baseline 21

transformers with today. It’s hinging somewhat on 22

equipment capacity. 23

The other point here is regarding th e life 24

cycle cost analysis and the fact that it’s free to 25Executive Court Reporters (301) 565

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use 90 percent M2 in certain cases, rather than 1

being limited by the supply. And I’m curious to 2

know what the outcome would be in terms of life 3

cycle costs if M3 were substituted for M2 in this 4

ana lysis, would it still be positive? 5

And my final comment/question is that 6

there was information provided to the DOE regarding 7

loading factors and whether or not that will play 8

into the sensitivity analysis or new life cycle cost 9

analysis, because when c ombined with the energy cost 10

and the loading, I don’t really

-- I guess I don’t 11

believe this, this life cycle cost. I don’t believe 12

that there is a big benefit for the nation to even 13

advance beyond where we’re at today. 14

MR. RABA: John. 15

MR. CASKEY: I don’t want to go back and 16

hash everything either, but okay, so when we did

-- 17

when the NOPR was released and we provided comments 18

on the NOPR, we had an opportunity to see those 19

scatter diagrams and to try and figure out what the 20

mix of stee ls were in those design lines and 21

efficiency levels. Is there

-- and I don’t know if 22

this is the same as what Greg had asked earlier, but 23

can we get the percentages that you’re rattling off 24

up there now for the different

-- for particularly 25Executive Court Reporters (301) 565

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the new effici ency levels, can we get those 1

percentages like within the next couple of days so 2

that we can factor that into our final comments that 3

we submit relative to this new analysis? 4

And I realize before he says anything, 5

that certainly the model is the model an d we’ve all 6

argued with the pros and cons of it, and you guys 7

are doing the best job you can to get in the right 8

ballpark, but where there are radical shifts, it 9

would be nice to know that it’s being produced by 10

the model because that drives everything els e. 11

MR. RIVEST: So

-- this is Mike Rivest. 12

Since everyone is bringing this up, I’m going to 13

have to say something. Remember, we are modeling 14

one KVA. We have modeled one specific voltage 15

primary, one specific secondary, one specific BIL. 16

I caution yo u to make radical predictions on steel 17

mix based on that, I mean, and dismissing experience 18

and what the knowledge of the people in this room 19

is. So to say that these are the facts and these 20

are the only facts, is incorrect. There are other 21

facts that we igh in this decision. We did not model 22

every voltage, every KVA, every BIL rating, and 23

that’s just the truth. 24

MR. deLASKI: So Mike, to follow on, that 25Executive Court Reporters (301) 565

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implies that you can’t estimate steel tonnage based 1

on your model. 2

MR. RIVEST: You know, I think t hat with 3

the precision we’re trying to have here that you 4

should rely on other information than just what’s 5

coming out of that. And that’s why when I hear, 6

well, what’s the mix coming out at EL

- 1.5, M2 versus 7

M3, we didn’t even model every kind of steel t here 8

is. We didn’t model every design

-- every way these 9

things can be designed. There’s a much more variety 10

in the market than what we can model. 11

MR. RABA: Steve R and then Steve N 12

afterwards. 13

MR. ROSENSTOCK: Steve Rosenstock, EEI. 14

Mr. Rivest I a ppreciate that but don’t you have to 15

rely on the information from the models to make the 16

ultimate decision? 17

MR. RIVEST: We have to rely on the 18

information in the docket. 19

MR. ROSENSTOCK: And the information that 20

you receive from stakeholders, yes, bot h? 21

MR. RIVEST: Yes. 22

MR. ROSENSTOCK: Thank you. 23

MR. NADEL: And actually my point

-- Steve 24

Nadel from ACEEE

-- and my point is picking up on 25Executive Court Reporters (301) 565

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that, basically we have one snapshot from this 1

Navigant analysis

. We have lots of other 2

information in the docket. What I heard John say is 3

he’s going to look at all that information. 4

Everybody recognizes crossover point is key, and we 5

look at that whole set of information and he decides 6

is it level zero, is it level 2.5 or where in 7

between is that crossover point. 8

MR. RABA: Deep breath. Should we 9

proceed, Chris. 10

MR. BOLDUC: Yes, thank you. So these are 11

the results for DL

- 3, and this is where we added the 12

pole replacement algorithm. So we used the same 13

methodology that we used in DL

- 2. We went back t o 14

RS

- means 2011, the same source for our pole 15

replacement estimates that we used in the NOPR. We 16

increased the pole replacement cost by the

-- adding 17

an additional crew, I believe it’s called a heavier 18

crane, to increase the overall pole replacement 19

cost. This pushed the distribution from around 20

$5800 up to close to $8000 per pole replacement. 21

We also scaled the weight change out 22

thresholds. So we took the 150 pounds that was used 23

for DL

- 2, we scaled it with the .75 scaling rule up 24

to 1418 pounds. Now I’m going to be very honest 25Executive Court Reporters (301) 565

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here, perhaps a bad thing, but we found that the 1

actual number of pole replacements with this 2

configuration was negligible, less than two percent. 3

The factor that came down to it was the minimum 4

weight threshold of 1418 pounds

. 5

Now also in this meeting, Carlos 6

maintained that for these larger KVA transformers, 7

they’re usually mounted on platform type 8

installations. That was not clear to me when we 9

were doing the analysis. Looking through product 10

catalogs, we did find man y mounting brackets that 11

would hold up to 6000 pounds of transformer for each 12

arm, so that’s based on

-- this is not based on 13

using a platform, it’s based on poles. Steve. 14

MR. ROSENSTOCK: Steve Rosenstock, EEI. 15

In the new appendix 1A that you put out, you show, 16

in table 1

- A.3.4 you talk about summary of weight 17

for pole mounted design lines by efficiency level. 18

And it looks

-- and again, you show minimum, 19

average, and maximum, and the average

-- I’ll just 20

use the average values for now

-- that was 22,8 12 21

pounds, and you do the scaling and it says, well, it 22

won’t be until 1400 pounds, that’s 4200 pounds and 23

based on the data that you have in this appendix, it 24

says you don’t get to that until efficiency level 7. 25Executive Court Reporters (301) 565

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MR. BOLDUC: As I said, it’s a shortcomin g 1

that we would like comment on. 2

MR. ROSENSTOCK: Okay. And again, I think 3

you received some comment that the delta

-- 4

sometimes the delta of the transformer isn’t as 5

important as a certain weight limit on the pole. 6

That even if you only go up a couple hundred pounds, 7

if that’s enough to get to the structural weight 8

maximum of the pole because of the other utilities 9

on the pole, for example, in utility areas, just 10

that small delta based on everything else could lead 11

to the change out . I know the modeli ng and you’re 12

scaling it, but again I think we’ve sent you 13

information, the fact that especially in urban areas 14

with combined utilities on the same pole, that it’s 15

not just the delta of the transformer, it’s the 16

delta to certain structural maximums on the pole. 17

MR. BOLDUC: Thanks. 18

MR. ROSENSTOCK: Again, I have to be 19

honest, I want to be fair. I’m not sure how you 20

model that. You might want to say for a percentage 21

of the poles, especially if you have a

-- if there’s 22

some way to analyze urban versus n on

- urban poles, 23

that might be one way to do it in terms of some of 24

your analysis. If there’s a way to find that data 25Executive Court Reporters (301) 565

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out. 1

MR. BOLDUC: Thanks, Steve. Moving on to 2

DL

- 4. Again what we’re seeing here is pretty much 3

an extension of the NOPR analysis, wha t we would 4

expect. At around EL

- 2 we do see the switchover in 5

the LCC picking amorphous, that’s why we see the 6

decrease in payback periods. 7

And likewise in DL

- 5. Robert. 8

MR. BERMAN: Robert Berman, Berman 9

Economics. Can we go back? I’m processing a little 10

slowly today. 11

MR. BOLDUC: Sure thing. 12

MR. BERMAN: Why do the payback periods

-- 13

why is the chart U

- shaped on efficiency levels? 14

MR. BOLDUC: The payback, yes. This is 15

because we’re seeing a transition to amorphous. 16

MR. BERMAN: That

-- 17

MR. BOLDUC: Around EL

- 2. 18

MR. BERMAN: That talks about a decline, 19

and then the

-- going back up again is? 20

MR. BOLDUC: That’s the increase

-- if you 21

remember the engineering curves

-- 22

MR. BERMAN: Increased costs. Okay. All 23

right, and that

-- t hat’s fairly flat, then. Okay. 24

MR. BOLDUC: Aaron? 25Executive Court Reporters (301) 565

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MR. MEYERS: Aaron Meyers, Cooper. 1

Looking at design line 5 here and the mean retail 2

cost, in EL

- 1 it’s $28,000 and change. EL

- 1.5 it’s 3

$25,000 and we generally see the cost of the 4

transformer goi ng up with the efficiency level. And 5

so I’m wondering is that responsible for driving 6

this payback period for the transformer of 1.1 years 7

which kind of seems unbelievably good, I guess. 8

MR. BOLDUC: Yeah, that looks

-- it does 9

look

-- 10

PARTICIPANT: S uspicious. 11

MR. BOLDUC:

-- suspicious, thank you. I 12

don’t have an explanation for that, Aaron, I’ll have 13

to take a look at the model just to make sure 14

everything is reported correctly. Thanks. 15

National Level Impacts: NIA Result s 16

MR. BOLDUC: So wha t we have here is we 17

have the proposed standard in green, and we have 18

additional TSLs A, B, C, and D off on the right. As 19

you can imagine, what we’re seeing here is we’re 20

actually across the proposed TSLs or the new TSLs, 21

we are seeing an extension that w e would expect from 22

the LCC results that were fed in there. Do you have 23

any questions? Jerry. 24

MR. CORKRAN: Jerry Corkran, Cooper Power. 25Executive Court Reporters (301) 565

- 0064 101

Regarding your proposed TSL

- 1 what did your 1

calculations show for the percentage of amorphous 2

and percentage of gr ain

- oriented core steel? 3

MR. BOLDUC: For TSL

- 1? I don’t have 4

those numbers. I’m sorry. Steve. 5

MR. ROSENSTOCK: Steve Rosenstock, EEI. 6

Just to clarify, on the second line of that, where 7

it says equipment cost, that’s the change in 8

equipment cost co mpared to the base, right? 9

MR. BOLDUC: That’s right. 10

MR. ROSENSTOCK: Thank you. 11

MR. BOLDUC: Yes. Okay. So 12

disaggregating these national level impacts to give 13

an illustrative overview of what the savings might 14

be for pads and poles as separate eq uipment classes, 15

the Department basically assumed a 70:30 split. 16

It’s a very rough estimate for the impacts of the 17

pole mounted or

-- sorry, equipment class 1A, which 18

is the all other equipment class, and 1B. A number 19

of reasons for this: one, at the ti me, we did not 20

have the disaggregated data that we needed to 21

separate the shipments by pads and poles, and also 22

we wanted to go forward with the NOPR tools. So 23

these numbers are very soft. I’d just like 24

everybody to keep that under consideration. 25Executive Court Reporters (301) 565

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Likew ise, for the three phase, we assume 1

that 95 percent of the savings would be attributed 2

to the pad or all other three phase transformers; 3

only five percent would be attributed to three phase 4

pole mounted. 5

So, in summary, for TSL A, which is very, 6

very clo se to what the proposed standard was, we’re 7

looking at point four five (0.45) quads of savings, 8

NPV of close to .93 billion at seven percent, and 9

4.66 at three percent discount rates. For most 10

equipment classes we have a net benefit greater than 11

60 percen t. These are based on the LCC numbers. 12

In terms of the physical changes in the 13

transformers which I know people are very concerned 14

about, we’re showing a weight increase of between a 15

four percent for DL

- 3 and a ten percent weight 16

increase for DL

- 2. Aar on. 17

MR. MEYERS: I did look at 25 KVA poles 18

and 50 KVA poles, only poles, because that’s what 19

we’re primarily concerned with here, and to go to 20

EL

- 2 and keeping with M3, there was a 40 percent 21

increase in weight for both of them. So I just 22

figured I’d t hrow that out as a piece of information 23

as the DOE’s looking for feedback. 24

MR. BOLDUC: Sure, can you include that in 25Executive Court Reporters (301) 565

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the written comment afterwards? 1

MR. MEYERS: Sure. 2

MR. BOLDUC: Thanks. Steve. 3

MR. ROSENSTOCK: Chris, again, thank you 4

for this information, but I just want to double 5

check. You said the volume increase of 14 percent. 6

When you say footprint, that’s length by width

-- 7

MR. BOLDUC: That’s right. 8

MR. ROSENSTOCK:

-- in terms of pad? 9

Okay, I just wanted to double

- check

. 10

MR. BOLDUC: And likewise, moving on to 11

TSL B. We’re looking at point six (0.6) quads of 12

savings, and 1.2 billion in NPV at seven percent, 13

with 6.4 billion at three percent discount rates. 14

And again, we don’t see a large change in the pole 15

mounted transf ormers, I believe. We do see a larger 16

change in the single phase pad mounts in terms of 17

weight. Volume increases are all quite small. 18

But we do see a change in the materials 19

mix in the very bottom line. I can read this out, 20

but everybody looks like they’re reading it

-- able 21

to read it just fine. Robert. 22

MR. BERMAN: Robert Berman, Berman 23

Economics. Could you say a few words about how 24

those percentages are calculated on the results, the 25Executive Court Reporters (301) 565

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last line on the slide. I’m not sure

-- I’m trying 1

to do th e

-- I’m trying to visualize the 2

calculation. 3

MR. BOLDUC: So this is the sampling

-- 4

sorry. These are the results from the LCC sample, 5

the percentage of units selected by the LCC at each 6

EL for each design line. 7

MR. BERMAN: Okay, so these are the 8

percentage of units

-- 9

MR. BOLDUC: That make up the simulation. 10

MR. BERMAN:

-- that make up the 11

simulation? 12

MR. BOLDUC: Sorry, the simulated results. 13

MR. BERMAN: So that’s what’s included in 14

the sample space, not what necessarily wins? 15

MR. BO LDUC: This was what was selected by 16

the LCC. There are many more materials inside the 17

sample space, but this is the percentage of core 18

materials that was sampled by the LCC. 19

MR. BERMAN: Selected as least cost or? 20

MR. BOLDUC: Yes, lowest least cost or 21

lowest TOC . These numbers are available on the 22

summary results tab of all the LCC worksheets, 23

workbooks. Greg. 24

MR. COULTER: This is Greg Coulter. I 25Executive Court Reporters (301) 565

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have a question. If I just look at TSL A and B up 1

there. 2

MR. BOLDUC: Yes. 3

MR. COULTER: The e fficiency class 1A and 4

1B. 1B is poles. Between TSL A and TSL B, the 5

efficiency levels are exactly the same. 6

MR. BOLDUC: That’s right. 7

MR. COULTER: But

-- 8

MR. BOLDUC: The savings are different. 9

MR. COULTER: The savings are different. 10

MR. BO LDUC: That’s right. That’s an 11

artifact of the rough 70:30 split, or 95:5 split I 12

mentioned earlier. 13

MR. COULTER: But you have that covered 14

under equipment class B, right? I’m not too sure, 15

you know, one’s poles. Poles didn’t change, only 16

pads would change

-- 17

MR. BOLDUC: That’s right. 18

MR. COULTER: Why does a pad change affect 19

a pole change? 20

MR. BOLDUC: We didn’t have the numbers to 21

change the NIA

-- we didn’t have the specific pole 22

versus pad by KVA rating in terms of shipments to 23

modify the NIA to give you a more accurate answer. 24

Right now, these are illustrative numbers that we 25Executive Court Reporters (301) 565

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think this is what is possible. It’s a long way of 1

saying we took equipment class 1 and we split it 2

70:30 at each TSL for poles and pads. 3

MR. CYMBALSKY: And we’l l take comment on 4

what those percentages

-- 5

MR. BOLDUC: Oh, yeah, we’d love those 6

numbers. 7

MR. CYMBALSKY:

-- should be. If you 8

think they’re different, we’d love to know what they 9

are. 10

MR. COULTER: My comment is simple. Once 11

you know the percentage, it don’t change whether 12

you’re an A, B, C, or D. So your pole class up 13

there should not have changed whether I’m in A, B, 14

C, or D. That’s my point. So no change in 15

efficiency should have been no change in the energy 16

savings. 17

MR. BOLDUC: W ell, I understand, Greg. I 18

thought my

-- I mean whether it’s 60:40, I don’t 19

care, 70:30, 80:20, those numbers shouldn’t have 20

changed. That’s all. 21

MR. COULTER: I don’t see how those 22

numbers could change with no change in efficiency. 23

Same volume. 24

MR. BOLDUC: I don’t have those volume 25Executive Court Reporters (301) 565

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numbers, Greg. This is my point. Andrew, I 1

understand you ha d a written comment. Does this 2

answer your question? 3

MR. deLASKI: It doesn’t, but I’ll keep 4

puzzling over it. 5

MR. BOLDUC: Okay. Thanks. TSL C, which 6

we’d like to state was the advocates final position 7

from the R eg N eg, which we finally have here today. 8

PARTICIPANT: (Comment off mic rophone ) 9

MR. BOLDUC: I’m trying. That would save 10

roughly 1.3 quads over the analysis period. NPV of 11

2.99 billion at seven percent, and 13.51 billion at 12

three percent. And again, the physical 13

characteristics. Do I have any questions? 14

MR. ROSENSTOCK: So, Chris, this is Steve 15

again. At the bottom there, again, just based on 16

the model it’s basically either 79 to 1 00 percent 17

amorphous? 18

MR. BOLDUC: That’s right. 19

MR. ROSENSTOCK: Across all design lines, 20

right? 21

MR. BOLDUC: That's correct. 22

MR. ROSENSTOCK: And then the other part 23

is M2? 24

MR. BOLDUC: Yep. 25Executive Court Reporters (301) 565

- 0064 108

MR. ROSENSTOCK: Thanks. 1

MR. BOLDUC: And again, TSL D, which is a 2

modified version of TSL C, if you will. Where we’re 3

seeing 1.2 quads of energy over the analysis period, 4

and 12.93 billion in savings at seven percent, and 3 5

billion at three percent. Thank you. 6

So moving on to the comments sought

-- 7

shall I keep going? So for this, you know, we’d 8

really like to reiterate that we’re

-- after your 9

comments on the new equipment classes, the new ELs, 10

we also

-- well, we’re seeking comment on all 11

aspects of this analysis for the final rule. In 12

particula r, comments on 13

the new equipment classes, pole / pad, 14

network / vault, 200 KVA, BIL, any new TSLs. 15

Opportunity for other energy savings. 16

The appropriateness of efficiency levels for 17

each class 18

The pole replacement costs, which I believe 19

I’ve gone over 20

And the shipments data of all types. 21

Robert. 22

MR. BERMAN: Robert Berman, Berman 23

Economics. One thing I haven’t seen in this that 24

would seem to be pretty relevant to think about 25Executive Court Reporters (301) 565

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is potential for substitutability. That is to 1

say, take the 200 KV BIL class for example. If I 2

hold that, just for the sake of argument, if I 3

hold that at EL

- 0 and increase 150 to El

- 2, am I 4

better off buying

-- is it cheaper for me to buy 5

a 200 KV BIL when what I really need is a 150? 6

Do I create distortions on that? Similarly , I 7

guess I don’t have any

-- problem doesn’t appear 8

to come up with poles and pads, because I can’t

- 9

- I can’t use a pole transformer on a pad, I 10

guess, even if I run the wires up and down. But 11

for bulk transformers if I take a look at the 12

minimum requir ements for a vault, according to 13

the specs, rather than the price of a typical 14

vault transformer which likely includes lettuce, 15

tomato, pickle, and onion , is it cost effective, 16

is there a trade

- off on cost or what is the 17

tradeoff on cost for vault versus p ads? Here we 18

don’t have a

-- our current mix data doesn’t help 19

us because if we’re going into a type of 20

transformer that’s technically substitutable, and 21

start changing efficiencies and relative prices, 22

we might get the market responding in ways we 23

never thought of before. And I’m just interested 24

in what opportunities there might be for that 25Executive Court Reporters (301) 565

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response. 1

MR. BOLDUC: Thank you. Tim. 2

MR. BALLO: Tim Ballo, Earth Justice. 3

Just following on to Robert’s comment. I think 4

during the workgroup that develope d the 5

definition for the network and vault 6

transformers, we had some data from ABB and from 7

Progress Energy that suggested that there was a 8

fairly significant price premium for vault units 9

meeting the IEEE standard. However, as was 10

pointed out on one of t he earlier slides, 11

something like 90 percent of vault transformers 12

use a very high quality steel. And if I was a 13

utility and wanted to buy a really low cost 14

transformer, if I were to order one meeting the 15

IEEE vault requirements but not having that high 16

q uality core, what would the cost differential 17

be? And it seems like there’s an awful lot of 18

potential here for a submersible transformer 19

meeting the IEEE requirements to be sold and 20

installed on a pad. So I’m wondering, is there 21

any analysis available fo r what that cost 22

differential is for just meeting the submersible 23

requirements? 24

MR. RABA: Wes. 25Executive Court Reporters (301) 565

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MR. PATTERSON: Wes Patterson. My 1

understanding was that the existing standard 2

already applies to the networks, so they can’t be 3

made any lower than the existing standard. And 4

to comply with the existing standard has already 5

forced those products into the high grade steel. 6

MR. BALLO: So I guess my question is, are 7

they using the high grade steel to meet the 8

standard within the dimensional constraints o f 9

fitting into the vaults? 10

MR. PATTERSON: And the answer to that is, 11

yes. 12

MR. BALLO: Okay, but if I’m producing a 13

unit that while having to be submersible, 14

wouldn’t have to fit into the vault, do I then 15

have to use the high grade steel? If I’m 16

produ cing a unit with the purpose of, although 17

it’s name plated as a vault unit, it’s nudge, 18

nudge, going to be sold and installed on a pad. 19

It seems like I wouldn’t have to still use the 20

high grade steel at that point. 21

MR. PATTERSON: There’s a couple of 22

dimensions to answer this question. One is you 23

cannot install a unit designed as a network or a 24

vault on a pad. If we’re talking about pad mount 25Executive Court Reporters (301) 565

- 0064 112

transformers. Because those are in publicly 1

accessible areas and these u nits are not designed to 2

be safe for access to the general public. By 3

compliance with that standard, they cannot be 4

physically deployed in a pad installation. One 5

could say, okay, you’d be crazy enough to put one in 6

for a substation transformer in restri cted access 7

area, however the cost of these units run 80 percent 8

more than a standard transformer, because of all the 9

other requirements within the standard. Not just

-- 10

I mean, even before we went into the high grade 11

steel, these things carried an 80 per cent premium to 12

them. 13

MR. HIRSCH: Let me interrupt? 14

MR. RABA: Go ahead. We have an answer 15

here, perhaps? Thank you, Wes. 16

MR. HIRSCH: Bruce Hirsch, Baltimore Gas 17

and Electric. I don’t know if I have an answer, but 18

from a utility standpoint, I ca n tell you that I’d 19

much rather put a pad mounted transformer up than to 20

put a submersible unit. Submersible transformers, I 21

mean we talk about the weight of the steel and 22

everything, quite honestly, the maintenance of 23

anything that’s underground is extre mely high, so 24

there’s just a tremendous amount of cost. I just 25Executive Court Reporters (301) 565

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don’t believe that any utility would take a vault 1

design and put it on a pad somewhere, don’t make any 2

sense at all. Utilities would try to put a pad 3

mount transformer in a vault, but it’s bo ught by the 4

pad mount standards, and quite honestly, wouldn’t 5

last very long because of the corrosion issues. So 6

I think those are the things that you really need to 7

take into account. There’s a direct difference 8

between a network or a vault type transfo rmer than a 9

pad mount transformer , from the utility’s point. 10

The other thing I’d like to point out too 11

is, from the utility’s standpoint that has a big 12

city, Baltimore, we don’t have an option. We are 13

told we will be putting things underground, so we’ re 14

mandated to go with the networks and the vaults we 15

buy, and we are not expanding that system at all. 16

Very few units are bought for new installations. 17

They all

-- most of what we buy are replacement 18

installations, that’s the size limitations that we 19

ru n into in the discussions that we’ve had. 20

So I think it’s important to know. I 21

think most of the utility business in networks and 22

vaults is replacement type transformers, and using 23

one for the other just

-- it just doesn’t make any 24

sense financially to a utility to do that. 25Executive Court Reporters (301) 565

- 0064 114

MR. RABA: Perhaps you had an answer. 1

Thank you very much. It was very helpful, Bruce, 2

thank you. We have a caller on the line waiting, 3

Kevin Alman. You’re live, go ahead, sir. 4

MR. OEHLMANN : Thanks. Kevin Oehlmann 5

from Con E dison in New York. Just to kind of, I 6

guess, tie into what

-- hello, can you hear me? 7

MR. RABA: Yes, we can. 8

MR. OEHLMANN : Just to tie in to some of 9

what the individual from Baltimore was saying. We 10

have approximately 26,000 network transformers 11

in stalled throughout New York City . We cannot 12

install those on pads and we do not put pad mount 13

transformers in vaults. The cost associated with 14

expanding vaults, if we could do that, would be 15

quite high in New York City, just because there is 16

no real esta te to do so, and it would have a 17

significant financial impact to our rate payers, 18

should we have to go in that direction. 19

MR. RABA: Thank you. Very helpful. Very 20

helpful. Thank you, Kevin. Bob Berman. 21

MR. BERMAN: Robert Berman, Berman 22

Economics. I understand it’s not cost effective to 23

put a pad in a vault, for exactly the reasons you 24

say

-- suggest. But if I were to make a pad vault 25Executive Court Reporters (301) 565

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transformer accessible or non

- accessible, for 1

example, if I put a hood on the only thing that’s 2

showing to the pub lic, on the connectors on top, so 3

that was basically locked down the same way as a pad 4

transformer is locked, could I not put it on a pad 5

if it was cheaper to do so? Again, Jerry’s quite 6

correct, I’ve never designed a transformer, but the 7

question is, how is the market likely to respond if 8

we start changing cost significantly. We’ve got a 9

set of IEEE standards that were set up, that says 10

nobody puts vault transformers on pads and nobody 11

puts pad transformers in vaults, and this is what 12

you’ve got to do to have the electronics correct, 13

this is what the standard is. Those standards do 14

not, nor should they try to conceive of what happens 15

if, through regulation, we decide to distort 16

relative prices dramatically. And my question is, 17

what happens if, through r egulation, we distort 18

relative prices? And what is the amount of 19

distortion in relative prices that we’re talking 20

about? So I think we need to calculate what that 21

is, and that’s not a question of what does a typical 22

vault transformer sell for, or what do es a typical 23

network transformer sell for. That is, what do I 24

have to do to qualify something as a vault under the 25Executive Court Reporters (301) 565

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standard? 1

MR. RABA: Thank you, Robert. We have 2

several hands up. We have one caller who was first, 3

David Millure, go ahead, we’ll put y ou live. 4

MR. MILLURE: Thanks. Dave Millure, 5

Metglas. We were talking earlier about the 200 BILs 6

for the vaults and I think Greg Coulter said that we 7

should move that down to 150. My question is, if we 8

move it down to 150 and carve that out, then if y ou 9

want to buy a 125 at some new higher efficiency 10

standard, versus a 150 at the existing efficiency 11

standard, would not the 125 BIL higher move to a 12

150? So you’ re talking market size. We heard about 13

five percent for the 150 and above, maybe we should 14

t alk a 25 percent, whatever it is, for the 125 and 15

above, would be the actual impact of that carve out. 16

Thank you. 17

MR. RABA: Thank you. We’ve got more 18

hands coming up. Let’s take these in turn, please. 19

I think you were next, Andrew. 20

MR. deLASKI: G o ahead. 21

MR. RABA: Okay, passing on. Jerry. 22

MR. CORKRAN: Regarding the different 23

equipment classes that we discussed

-- 24

(comment off mic rophone ) 25Executive Court Reporters (301) 565

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MR. CORKRAN: Good point, any comments on 1

the comment. 2

MR. COULTER: I would like to comment 3

becau se he mentioned me. 4

MR. CORKRAN: Go ahead Greg. Greg 5

Coulter. 6

MR. COULTER: This is Greg Coulter. I 7

think Dave Millure has an excellent point, actually. 8

It’s a point we’re concerned about. If you would 9

suggest that 150 BIL was the new cutoff rather than 10

200, well, people would just start ordering 11

everything as 150 BIL and get a lower efficiency. 12

So we’d be concerned about that too. There’s ways 13

to cover that. The easiest way, it’s really a 14

voltage issue. BIL is a simple way of talking abou t 15

this for purposes of meeting like this, but there’s 16

certain voltages have to be 150 BIL, and there’s 17

certain voltages do not, and we’d really make that a 18

voltage cutoff, not a BIL cutoff. At least that 19

would be my suggestion the way that’s handled. 20

The se voltages are 150 BIL and above and they would 21

be subject to different efficiency levels than these 22

other voltages. And you cannot use the wrong 23

voltage in these cases. Thank you. 24

MR. RABA: Thank you. And now are there 25Executive Court Reporters (301) 565

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additional

-- I think you wer e going to

-- Bruce, 1

you had something there? 2

MR. HIRSCH: Yes, Bruce Hirsch, Baltimore 3

Gas and Electric. Just answering Bob’s comments 4

before. I think in one of these meetings earlier, 5

somebody likened it to using a Sherman tank when a 6

Chevy Cruiser w ould do. That’s essentially what 7

you’d be talking about if we were using a network 8

transformer. Inherently they’re more expensive 9

because of the thickness of the steel, and it’s 10

built that way to withstand subsurface requirements. 11

Certainly I’m not naïv e enough to say that somebody 12

wouldn’t use a tank to drive back and forth to work 13

once in a while. So it’s possible. It certainly is 14

possible that you can take a network transformer, 15

make it safe enough and set it out in the open. 16

It’s hard to believe t hat anybody would do it. 17

And I think also that if that’s ever done, 18

what happens is it now doesn’t meet the requirements 19

of a network, it’s got to meet the requirements of a 20

pad mount, and it would fall under the auspice of 21

the efficiency standards th at were required. But 22

anyway, I think you’ve just got to understand the 23

differences there. Can somebody misuse equipment, 24

certainly they can, but I think in this case it’s a 25Executive Court Reporters (301) 565

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big if. It’s a big if. 1

MR. RABA: We saw over here. Go ahead, 2

please. 3

MR. HOFFMAN: Alex Hoffman, American 4

Public Power Association. I was just going to 5

reiterate it based on conversations with various 6

municipal utilities, especially since Wes just 7

mentioned that we were talking about a transformer 8

that’s 80 percent more expens ive by design. So it’s 9

not just price, and I hope

-- presumably this 10

standard is not intending to raise the cost of a 11

transformer by 80 percent. But there’s also like 12

was mentioned, safety issues, these are very 13

serious, and they have legal ramifications . There’s 14

good design issues, so it’s really not efficient to 15

put these vault

-- pad transformers in vaults, 16

because the life cycle of your equipment receives a 17

major impact there. As it is designed and installed 18

-- or designed by an electrical engineer, there’s 19

licensing implications. So the engineer has an 20

ethical obligation not to do something like this and 21

can

-- there’s a ramification. There are sets after 22

sets after sets of ramifications for mis

- installing 23

a vault

-- a pad transformer in a vault. And so I 24

just thought I would reiterate that because I think 25Executive Court Reporters (301) 565

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it’s really important point in this discussion. 1

MR. RABA: I saw Andrew first, or are you 2

going to comment on these also, Andrew? 3

MR. deLASKI: Yes, I guess I would just 4

try to summarize by saying, you know, we have 5

expressed in the past that we are comfortable with, 6

if DOE does go to standards that are significantly 7

higher than what has been proposed with separating 8

out classes. But I think the point’s been raised 9

today suggest that there’l l need to be a hard look 10

at the definitions to make sure that we’re not going 11

to abuse it. I hear you Bruce. A network 12

transformer

-- we’re not that worried about that 13

based on our review of IEEE. The vault definition, 14

we’re not sure the IEEE definition is as tight

-- 15

certainly it’s not as tough as the network 16

definition. So the vaults give us a little bit of 17

pause, and we would like a hard look at that 18

definition and urge the Department to do so as well. 19

Is the vault definition tight enough. 20

And the n to avoid someone

-- the market 21

changing in a way that we don’t anticipate, so it’s 22

the unanticipated consequences that we’re trying to 23

avoid here. And Greg, thank you for your suggestion 24

of voltage. I think

-- and we’re also very 25Executive Court Reporters (301) 565

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concerned that 150 tha t that just becomes not five 1

percent, but the whole market. So there’s going to 2

have to be something tighter on that. So I think if 3

we go with high BILs, 200 doesn’t seem like much of 4

a risk, or go to 150 then that’s going to have to be 5

controlled in som e other way. And again, if we’re 6

talking about higher levels, I think it’s totally 7

appropriate to have those conversations. 8

MR. RABA: First Robert, then Bob, then 9

Steve. Then I think we’ll get back to cue you 10

Jerry. 11

MR. BERMAN: It’s really importan t to look 12

at the costs on this, and the importance of cross

13

substitutability. We’ve already got a huge hole in 14

the regs now on pad transformers in that step up 15

transformers for wind aren’t covered. If I buy a 16

wind transformer, I can use it on a distribut ion 17

network. The

-- whether or not this is done or the 18

extent to which it’s being done, I don’t know. But 19

the

-- in looking across, trying to see what the 20

costs are, I was a little surprised to see in terms 21

of selling price that the network transformers were 22

just a little bit more expensive than non

- network 23

vaults, with a whole lot more electronics on them. 24

And I’m wondering if a lot of these

-- the question 25Executive Court Reporters (301) 565

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is, are a lot of these vault transformers being 1

purchased with switchgear that would not be 2

purch ased on pad mount transformers necessarily, and 3

that are not required to meet the IEEE definition of 4

a switch. 5

In looking at that, it seemed to me that 6

Yeah, the case has to be

-- is a lot more expensive. 7

I took a look at a copper bearing steel tank tha t 8

was maybe much thicker, three times the cost of the 9

existing tank. Everything that I can come up with, 10

other than the electronics which, as Jerry points 11

out, I don’t design transformers so I don’t know 12

about. I can get up to a ten percent difference in 13

cost by goosing some of those items. That tells me 14

that there’s a lot more in what’s being sold as a 15

vault transformer than is absolutely required to 16

meet the specs. So the concern is, is it possible 17

within the standard, to put a sign on something that 18

says, this is a vault transformer because it meets 19

this standard, and sell it in the market as a pad? 20

MR. RABA: Bob? 21

MR. SAINT : It seems to me that you’re 22

drawing at straws trying to come up with something 23

that really has no validity. I don’t think that 24

electric utilities are going to misuse, misapply 25Executive Court Reporters (301) 565

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transformers. They’re just not going to do that, 1

because of the reasons stated in this room. 2

However, there is another thing that maybe 3

should be concerned about, even more than this is 4

the use of r ebuilt transformers, to save money, and 5

that may be

-- to me, that’s more of a

-- that’s 6

more likely to occur than a utility misusing a new 7

transformer. And certainly that is a valid concern 8

that has been addressed in this room before because 9

they’re not under this rule. And as the prices go 10

up, more and more utilities are going to be looking 11

at rebuilt transformers rather than buying a new 12

transformer, because of the size requirement that 13

may occur, and the efficiency drives the cost up too 14

much. 15

MR. C YMBALSKY: Thanks, Bob. We’ve been 16

through that set of bushes, woods, and so I don’t 17

want to rehash that argument, please. 18

MR. SAINT : Thank you. 19

MR. RABA: That was helpful, Bob. First 20

Steve, then Kevin Oehlmann on the phone. Steve. 21

MR. ROSENSTO CK: Steve Rosenstock, EEI. I 22

hear the concern about possible substitution because 23

one type of transformer might have a higher standard 24

compared to the other, and involved would be the 25Executive Court Reporters (301) 565

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baseline, which by the way, is increased based on 1

the 2007 standards. They all

-- all their standards 2

went up as a result of the final rule in 2007 that 3

took effect in 2010. So the standards for networks 4

and vaults actually have gone up as result of the 5

2010 standard. So they’ve already had an increase 6

in efficiency beca use of the last rulemaking. 7

That’s one thing to consider. 8

The second thing, just to summarize, 9

there’s a lot of regulations where you’re not 10

allowed to build

-- put a pad mount transformer in a 11

city. It’s just not allowed. Thou shalt put it 12

undergroun d. Baltimore, New York, other cities, 13

even other new smaller cities, you know, a lot of 14

them have plans where you’re putting infrastructure 15

underground for aesthetic reasons. So even if the 16

economics said well, put in a pad or substitute it, 17

the local re gulations say, thou shalt not. Period. 18

You would violate the law, and utilities don’t like 19

to violate laws. Trust me on that one. Thank you. 20

MR. RABA: We’ll trust you, Steve. Thank 21

you. That was helpful. Kevin on the phone, please. 22

Go ahead. Yo ur turn. 23

MR. OEHLMANN : Thank you. Once again, 24

Kevin Alman in New York City. I guess I hear some 25Executive Court Reporters (301) 565

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discussions on, I guess in relation to the 1

definition of the equipment classes. I do have a 2

concern with the definition in the current language 3

for a netw ork transformers. As I mentioned earlier, 4

we do have 26,000 network transformers installed 5

here in New York City. That’s kind of an onus to 6

maintain. We are the single largest user of network 7

transformers in the United States. I believe Pepco 8

has betwe en 4500 and 5000, same thing with PSE&G, 9

and then the numbers go down from there. 10

The transformers that I specify do not 11

meet all the requirements of IEEE 6740, so that 12

seems to be discontinuity. And in some cases they 13

achieve the standard, but we don’t get a primary 14

switch compartment here at ConEd, that’s kind of 15

beyond the scope of this presentation anyway. But 16

certainly I would think that if there was going to 17

be a separate equipment class for network 18

transformers that the ones used here in New York 19

City should fall into that category. 20

MR. RABA: Thank you, Kevin. Impressive. 21

New York, of course. John. 22

MR. CASKEY: I’m not sure if we’ve beat up 23

this issue enough, but I mean I’m looking at the 24

slide there, and I’m prepared to give sort of a 25Executive Court Reporters (301) 565

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gen eral statement about, you know, that we certainly 1

-- if you’d like me to do that at this point. 2

MR. CYMBALSKY : Yes, that’s great. I 3

instructed Jim that we should close that topic down. 4

MR. CASKEY: Okay. So certainly we 5

appreciate DOE and Navigant a nd the rest, and LBL, 6

for all the work that they’ve done on looking at 7

these new equipment classes. Certainly we support 8

very strongly

-- NEMA

-- this is John Caskey from 9

NEMA

-- the idea of breaking out the poles and the 10

pads. We haven’t come to 100 per cent consensus 11

within NEMA because there are some manufacturers 12

that produce the poles and pads cores that are, you 13

know, basically the same, so if the efficiency 14

between the poles and the pads are the same, for 15

some of those manufacturers it makes it easi er on 16

the manufacturing process that they can use the same 17

components as to whether you’re using it as a pole, 18

or whether you’re using it as a pad. So there are 19

some benefits there. 20

But beyond that, certainly there are 21

weight and height restrictions ass ociated with 22

putting a transformer on a pole, and breaking out 23

the efficiency standard different from between a 24

pole and a pad makes some sense and allowing the pad 25Executive Court Reporters (301) 565

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efficiency standard to be higher than the pole makes 1

some common sense from our perspective

. 2

We’ll provide more detailed comments 3

before the deadline, which I think is the 26 th or 4

27 th on that issue. 5

MR. BOLDUC: The 29 th

. 6

MR. CASKEY: the 29 th . On the issue of 7

network and vault, we agree with Andrew when he said 8

that there needs to be some additional work done on 9

the definition, and we’ll provide some additional 10

help on that, dealing with wordsmithing, on the 11

definition of network and vault as well as where it 12

is submersible

-- the terminology submersible fit 13

into that, because from our perspective not all 14

vaults are necessarily submersible transformers. 15

And also we were talking about the 16

concerns of the vaults. And in my earlier life I 17

ac tually worked for Pacific Gas and Electric Company 18

as well as Virginia Power, and had been in quite a 19

few vaults, and I think the real driving force is 20

there, is that it is virtually impossible to modify 21

the size of the transformer that’s in there. I 22

mean , you basically have to rip out the side of the 23

building, or you have to do some major 24

reconstruction in order to put in a larger vault 25Executive Court Reporters (301) 565

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transformer than what’s already there. So I mean 1

that’s really the driving force in trying to leave 2

them even though th ey have increased in 2010, but 3

leaving that efficiency the same as what it is 4

relative to 2010. 5

The 200 KVA BIL, we’re still having some 6

discussions about that. Certainly, as Greg says, 7

the leaving it at the 200 KV BIL, there’s a very 8

small market out t here to deal with that. 9

Internally, to NEMA, we’ve talked about whether it 10

just should be terminology of greater than 95 BIL, 11

or whether it should be the 150 BIL that Greg has 12

talked about, so we’re trying to resolve that 13

internally and look at some of th e market shares and 14

things like that relative to that. But certainly 15

leaving it at the current 200 KV BIL doesn’t make a 16

whole lot of sense. So we will work on, you know, 17

what Greg has recommended dealing with the voltage 18

definitions and how they apply t o the different 19

BILs. 20

Certainly we’ve reviewed the new TSLs. 21

We’ll provide some comments on those. 22

Dealing with the utility pole replacement 23

costs, you know, that’s a utility issue, so NEMA is 24

not going to report on that. 25Executive Court Reporters (301) 565

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And the shipment data, we don’t have the 1

information as granular as you would like, so we 2

really won’t be able to provide the information for 3

that. Hopefully you can get it from other sources, 4

by working directly with the manufacturers. 5

So again, we appreciate the opportunity to 6

participate in this and breaking out some of these 7

different equipment classes, and we’ll provide 8

comments on all this stuff. Thank you. 9

MR. BOLDUC: Thank you, John. 10

MR. RABA: Chris, did you want to

-- oh, 11

did you want to say something, Jerry? 12

MR. CORKRAN: Jerry Corkran, Cooper Power. 13

The DOE had a request that we supply the percentage 14

pads and poles and the selling prices and all, and 15

our managers discussed it and decided that was such 16

confidential information that they didn’t feel like 17

discl osing that even though it might go to NEMA who 18

we love very much, of course, but still we’ve got to 19

keep it within the company. We won’t share that. 20

But one thing I admire DOE for trying to 21

get accurate information and would suggest, if we 22

think back o n the

-- when I read through the DOE 23

selection of 30 percent loading for single phase, 24

and 35 percent for three phase, and I go through 25Executive Court Reporters (301) 565

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that, I really would suggest that the DOE go to 1

Edison Electric, EEI and find out what loading

-- I 2

imagine they could g et 100 utility companies to tell 3

you exactly what their loading is. They’ve got the 4

metering, they’ve got the

-- and that’s such 5

critical to the calculations of your payback on the 6

loading, that if that’s incorrect and Wisconsin 7

Electric sent you a memo w here they said 42 percent 8

for single phase and 55 percent for three phase, and 9

that’s with 1.2 million customers

-- and that’s just 10

one company, but they’re telling y ou that your 11

loading is way off at 30 and 35 percent. And the 30 12

and 35 percent is like h aving an A to B factor of 13

eleven to one. And I’ve never seen a utility

-- and 14

if you think about utilities, they’ve got lots of 15

computers now, they know what they’re doing, and why 16

would they put a transformer in that’s only to be 17

loaded at 30 percent? T hey know what their loads 18

are. Thirty years ago they might not have known 19

what their loads are, but they do now. 20

And so I would request that you go back 21

and look at those numbers. It would be easy to 22

change calculations if you find out you don’t have 23

a ccurate numbers. I don’t think you do have 24

accurate numbers. But I request that you take a 25Executive Court Reporters (301) 565

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look at it. Get Steve to

-- I think Steve could 1

give you 100 utilities that would give them, 2

couldn’t you, Steve? 3

MR. ROSENSTOCK: No. By June 29 th , no. 4

MR. RABA: Thank you, Jerry. Should we 5

proceed on, Chris. Steve, let’s move on. 6

MR. BOLDUC: Those numbers can come in 7

past June 29 th

. 8

MR. ROSENSTOCK: Steve Rosenstock, EEI. 9

We don’t want to be blamed for DOE missing any 10

deadlines. No, thank you. 11

MR . BOLDUC: I’ll take the hit for you, 12

pal. No more comment extensions for you. 13

I’d like to thank you all very much. In 14

summary, it’s all up there. Your feedback is 15

requested by the 29 th of June. Thank you. 16

MR. CYMBALSKY: Thanks everybody for 17

com ing, we really appreciate it. 18

MR. RABA: Okay, from our part here, it’s 19

tradition to distribute evaluation forms. We would 20

like to hear from you about these proceedings and 21

how we an improve them. So pass these this way. 22

PARTICIPANT: I thought it we nt great. 23

MR. RABA: Okay. 24

(Whereupon, at 12:13 p.m., the meet ing in 25Executive Court Reporters (301) 565

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the above captioned matter was adjourned .) 1

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REPORTER'S CERTIFICATE

This is to certify that the attached proceedings

before:

U.S. DEPARTMENT OF ENERGY

In the Matter of:

PUBLIC MEETING ON ENERGY CONSERVATION STANDARD SUPPLEMENTARY ANALYSES FOR DISTRIBUTION TRANSFORMERS

Were held as herein appears and that this is the

original transcript thereof for the file of the

D epartment, Commission, Board, Administrative Law

Judge or the Agency.

Further, I am neither counsel for or related to

any party to the above proceedings.



### Wendy Greene

Official Reporter

Dated: June 25, 2012