From: Edwin Brush [mailto:ned.efbrush@gmail.com] 

Sent: Tuesday, October 11, 2011 8:31 AM 

To: Robert Berman; Phil Hopkinson 

Cc: Bob Smith; Caskey, John; Brian Coffey; Alex Hofmann; Andrew Delaski; Aris Marantan; Art 

Rosenfeld; Bob Saint; Caitlin Johnson; Carlos Gaytan; Charlie Drexler; Charlie Stevens; Chris Bolduc; 

Silcox, Clark; Creevy, Jim; Dan Cohen; Daniel Young; Eric Peterson; Freeman, Jeremiah; Gary Fernstrom; 

Greg Coulter; Greg Rosenquist; Hirsch, Bruce R; James Lass; Jennifer Tiedeman; Jerry Corkran; Jerry 

Hodge; Jerry Schoen; Joanna Mauer; John Cymbalsky; John Rossetti; Katie Coughlin; Ken Winder; 

Mahesh P. Sampat; Matt Miller; Matthew Nardotti; Meg Waltner; Meyers, Aaron; Michael Hyland; Michael 

Rivest; Millure, Dave; Phil Harter; Polinski, Raymond; Puesh Kumar; Rick Anderson; Rob Greeson; Robert 

van Buskirk; Robin Roy; Ryan, Paul; Scott Beck; Simmons, Chuck; Steve Nadel; Steve Rosenstock; Tim 

Ballo; Tom Eckman; Wes Patterson; Zhimei Luo; rjstahara@centralmoloneyinc.com; Ali Ghafourian; Dave 

Brender; jay.ballard@schneider-electric.com; Kenneth.Harden@schneider-electric.com; Tom Patzner; 

Steve Nizinski; Richard Parker 

Subject: Re: Distribution Transformer Loading and other Analyses 

Phil, Bob, et al, 

Loading levels are important, and most of this discussion appears to concentrate on current 

loading. 

 

The transformers that would/will be included in minimum efficiency standards will be installed 

and have a life in service of 30 to perhaps 40 years in the future, or longer. 

 

Future loading appears quite important for consideration and thoughtful inclusion in minimum 

required efficiencies. 

 

Current loading and loading patterns can be a baseline, and further energy efficiency 

gains among commercial, industrial and residential customers would be a factor in reducing their 

loading. HOWEVER, average residential loading since the 1950's has increased in recent years 

(one citing of DoE data has over twice the average consumption per household) - consider the 

current additional existing appliances, activities, penetration of central air conditioning, etc., 

compared to earlier decades. 

 

There are also current incentives and projections for large increases in numbers of electric and 

rechargeable electric vehicles for the future, as well as trends to time-of-day electricity pricing 

by utilities. (That could provide strong incentives to utilize the low rates proposed for late night 

hours). 

 

As late night usage grows, transformers have a heavier load at night - less opportunity to cool 

from perhaps the heavy daytime load from summer air conditioning, and probable higher rms 

load? -- consider the new system loading, not previously existing, from late-night vehicle 

recharging. 

 

My suggestion is to consider both current and historical loading and loading patterns, and 

FUTURE potential loading patterns. 

 

Then include "right-sizing" for transformers where applications permit. Right-sizing can reduce 

core losses (those continuous losses) - consider the 45 kva vs. 75 kva dry transformer, using the 
same grain-oriented steel, or amorphous; then, reduce conductor resistance appropriately to 

achieve higher overall transformer energy efficiency. 

 

Future loading for new transformer production may be significantly higher than current loading 

(while they are in-service for the next decades). 

 

Best regards, 

NED 

 

Dr. Edwin F. Brush, Jr. 

BBF & Associates, Consultants 

 

PS: Appliances currently available have delayed start, that can shift operating to late night 

further increasing late night loading; however, that is shifting load, where intent is to smooth 

loading patterns - and is not "new" loading such as the cited above electric and rechargeable 

electric vehicles being introduced and promoted. In addition, I have electric hot-water (at 

5,000KW/year - my Boston price is $0.22 ! - how much higher might it be in future?) - time of 

day pricing could lead many to use late night loading, and, if that KW pricing is low enough, 

perhaps to have electric hot water heating increase in market penetration in future years?? (using 

even more KW's per household) 

 

 

 

 

 

 

 

 

 

 

On Mon, Oct 10, 2011 at 10:49 PM, Robert Berman <bermaneconomics@gmail.com> wrote: 

Thanks for you response, Bob. 

I don't take issue with any analysis of how a transformer manages a load, or the technical aspects 

of how a transformer is designed to manage that load. The nature of that load, though, I accept as 

a given. In the LV meeting at the end of September, I was surprised to learn that the LV dry load 

was a low as it was. Couldn't imagine why anyone would deliberately oversize a transformer so 

inefficiently. A near-by engineer simply said "fire codes" and that immediately made sense. I 

was also directed to ASHRAE and related K-12 studies that assessed the likelihood of further 

falling loads due to increased efforts for energy conservation, and the need, for safety reasons, to 

maintain the capability for a full load on every outlet. I view that load as a reality -- a fact of life 

-- something as an analyst I cannot choose to disregard. I also see the load for measurement of 

efficiency, for manufacturer compliance purposes, as a separate and separable question. 

Although my own predilection is that the load for measurement "ought" to be the "real" load, I'm 
certainly prepared to hear arguments for doing otherwise; recognizing that they are not the same. 

What I am unwilling to accept is an argument that asserts a reality based on the regulatory 

measurement decision. That's at best backwards. Indeed, I would insist that the impact evaluation 

be done at the real load; possibly even considering some alternative measurement points on cost 

and efficiency given the real load. 

As far as a payback period is concerned, my own preference is for an incremental rate of return 

given my orientation to economics. However, since one is simply the reciprocal of the other, I 

have no objection if someone is more comfortable having gone to a different school. Some 

recognition of the cost of money, productivity of capital, and business risk is absolutely 

necessary, whether a hospital or cookie factory. The question, then, is the appropriate hurdle rate 

(or payback period) for the investment. In the case of energy conservation, a 3-year payback 

period seems inappropriate. That would correspond to a 33% return on investment, and is 

consistent with substantially higher costs of capital than we see in the current economy, and 

substantially greater risks than is present in an energy savings investment, whose only real 

private risk is a substantial fall in energy prices. Moreover, there are public benefits (e.g., 

environmental costs, impact on energy prices, etc) that is a fundamental part of the reason for 

Federal intervention in the market in this case. Those considerations would obviate for a criteria 

that may be different from the one some companies may use in their private, more risky 

investments. At this point, I would not recommend a particular PBP, but support one based on an 

appropriate assessment of the additional risk to consumer, with appropriate recognition for the 

additional, social return. 

With respect to an "economically justifiable" investment: generally speaking, it is one consistent 

with the opportunity costs -- with what you give up in order to have it. Similar to the reason for a 

hurdle rate, it is what a purchaser give up in order to have it (or not have it). If users (electricity 

consumes) made the investment decision, and there were no third-party benefits or costs, the 

decision would be rather straight forward. Energy Star appliances are a great example. The 

consumer looks at the difference in cost and efficiency, evaluates the efficiency at current energy 

prices, and decides whether it's a good buy.Nothing like that is available here: the consumer does 

not get to direct the utility's purchase, and there are other, non-market costs. The situation was 

beautifully illustrated by a conversation I had with the transformer purchasing manager at a 

major IOU. I pointed out that the energy savings associated with the incremental cost of an 

efficient transformer in a particular situation resulted in a return on investment of more than 80% 

annually (PBP= about 15 months), based on current energy prices alone. He agreed, but properly 

noted that his company and stockholders did not get it. Except for a very small return on the 

incremental investment, it all went to the ratepayer. And that doesn't even begin to address the 

environmental and other social costs. That's the reason for the Federal action. Cookie factories 

can figure out how to run their businesses w/o any Federal help or direction. 

Hope that helps. Look forward to seeing you Wednesday. 

Regards,

Robert A. Berman, Principal
Berman Economics

www.BermanEconomics.com

1915 Grand Court

Vienna, VA 22182

703‐281‐0490

703‐655‐8398 (cell)

BermanEconomics@gmail.com

On Oct 10, 2011, at 4:51 PM, Bob Smith wrote: 

Dear Robert:

Phil’s paper utilizes a lot of good and diverse loading situations.  I believe his analysis is going to be as

accurate as we’ll find anywhere.   Tom Paztner wrote an interesting follow‐up (attached) to his

comments during the last meeting.  His comments started me thinking about another source for loading

on 600 volt dry transformers.  That source, which has not been fully utilized, includes the many

consulting engineers (Fluor, Black & Veatch, Kiewit, Burns & McDonald, O’Neal, CH2MHill, etc.) that are

specifying the power ratings of the LV Drys based on their connected loads.  I’d encourage those doing

the technical loading analysis for this committee to utilize this source.  Phil’s data; however, may still be

much more valuable, because it is empirical by measurements actually made at installations.

Robert, in the area of economics I would value greatly your listing of attributes that fall into the category

of “economically justifiable”.  For instance, in the attached note that I sent last week I expressed great

concern that the “A” and “B” values were not appropriate for our ICI customers.   What do you think?  

How do you feel about the appropriate payback period for an incremental investment by a hospital,

paper mill, or a tire plant?  I would greatly value your input on these subjects.  For I am also searching

for the right answer to the equipment efficiency question, whether it be a gasoline engine, steam

turbine or a transformer.

Going back for a moment on your concern for the loading on transformers, I think I can say with almost

perfect accuracy, that if we establish efficiency levels another 1⁄2 percentage point higher for the Low

Voltage Transformers,  the consultants and end users, as they are faced with substantially increased

pricing, will definitely start buying smaller size KVA ratings with the effect that the loading as a

percentage  of nameplate rating will exceed the assumed 35% that we are now using.  For the sake of

energy conservation I don’t think this is a good outcome.

Sincerely,    

Bob Smith, PE

Product Manager

Federal Pacific

601 Old Airport Road

Bristol, VA 24201 
TEL: (276) 645-8836

FAX: (276) 645-8212

CELL: (276) 591-6143

Email: bsmith@federalpacific.com

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From: Robert Berman [mailto:bermaneconomics@gmail.com] 

Sent: Monday, October 10, 2011 2:40 PM 

To: Richard Parker 

Cc: Phil Hopkinson; Caskey, John; Brian Coffey; Alex Hofmann; Andrew Delaski; Aris Marantan; Art 

Rosenfeld; Bob Saint; Bruce Smith; Caitlin Johnson; Carlos Gaytan; Charlie Drexler; Charlie Stevens; Chris 

Bolduc; Silcox, Clark; Creevy, Jim; Dan Cohen; Daniel Young; Eric Peterson; Freeman, Jeremiah; Gary 

Fernstrom; Greg Coulter; Greg Rosenquist; Hirsch, Bruce R; James Lass; Jennifer Tiedeman; Jerry 

Corkran; Jerry Hodge; Jerry Schoen; Joanna Mauer; John Cymbalsky; John Rossetti; Katie Coughlin; Ken 

Winder; Mahesh P. Sampat; Matt Miller; Matthew Nardotti; Meg Waltner; Meyers, Aaron; Michael Hyland; 

Michael Rivest; Millure, Dave; Phil Harter; Polinski, Raymond; Puesh Kumar; Rick Anderson; Rob Greeson; 

Robert Berman; Robert van Buskirk; Robin Roy; Ryan, Paul; Scott Beck; Simmons, Chuck; Steve Nadel; 

Steve Rosenstock; Tim Ballo; Tom Eckman; Wes Patterson; Zhimei Luo; 

(rjstahara@centralmoloneyinc.com); Ali Ghafourian (aghafourian@ermco-eci.com); Ned Brush 

(Ned.efbrush@gmail.com); Dave Brender (dbrender@cda.copper.org);jay.ballard@schneiderelectric.com; Kenneth.Harden@schneider-electric.com; Tom Patzner (thomas.patzner@us.schneiderelectric.com); Steve Nizinski 

Subject: Re: Distribution Transformer Loading and other Analyses

 

Richard, 

 

I have carefully reviewed the HVOLT analysis. Although I am not an engineer, and will not 

comment on particular engineering designs, I am concerned about a number of the assumptions 

made regarding electricity utility system economics as well as the transformer prices. The latter 

appear at odds with published market data and appear to misquote the DOE PTSD. As the 

analytical conclusions appear to be riven by the assumptions, it is important to put the 

assumptions in their proper context. Attached are my detailed comments. 

 

<Patzner.doc><October 6.doc>