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

Sent: Wednesday, November 16, 2011 4:26 PM 

To: Meyers, Aaron 

Cc: Hirsch, Bruce R; Jerry Hodge; Steve Nadel; Robert Berman; John Caskey; 

Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; mhyland@appanet.org; 

Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; tpetrosino@carolina.rr.com; 

dbrender@cda.copper.org; James.Lass@cleco.com; chris.brown@cogentpowerinc.com; 

frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; Trujillo, Antonio; Moore, Jack 

C; Corkran, Jerry L; tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; 

Emily (CONTR) Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; srosenstock@eei.org; 

DYoung@energy-solution.com; rick.anderson@faypwc.com; bsmith@federalpacific.com; 

rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; 

greg.coulter405@gmail.com; ned.efbrush@gmail.com; Paul.Ryan@hitmet.com; Daniel Cohen; Phil 

Hopkinson; cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; 

dave.millure@metglas.com; kwinder@mleainc.com; jrossetti@mlgw.org; Brian Coffey; Caitlin Johnson; 

Matthew Nardotti; Michael Rivest; Zhimei Luo; Jim Creevy; mwaltner@nrdc.org; rroy@nrdc.org; 

robert.saint@nreca.coop; Teckman@nwcouncil.org; vijay.tendulkar@onyxpower.com; gbf1@pge.com; 

chuck.simmons@pgnmail.com; ahofmann@publicpower.org; pkumar@publicpower.org; 

adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org 

Subject: Re: Negotiated Rulemaking - Distribution Transformers Teleconference 

Colleagues, 

These are important concerns and I appreciate the thought behind them. As agreed in our prior 

meeting, DOE staff are consulting with industry and updating their data to refine and strengthen 

the analysis of the liquid-filled market to better reflect actual marketplace conditions. It may be 

helpful to withhold final udgment on these matters until the updated engineering and LCC 

analysis is released, which we hope and expect will be fairly soon, recognizing that this is a 

complex and difficult undertaking and it is important to get it right. 

I hope you have received the updated LCC analysis for MVDT, and I look forward to talking 

with you all tomorrow on the conference call. 

All best, 

Richard 

On Wed, Nov 16, 2011 at 4:07 PM, Meyers, Aaron <Aaron.Meyers@cooperindustries.com> 

wrote: 

Jerry,

We share the same concern regarding pandemonium in the industry. In addition, to my knowledge, no 

transformer manufacturer currently has enough amorphous capacity to support 100% of their DOEcompliant transformer sales. Yet the DOE analysis shows that at EL2, the core steel demand would 

essentially be 100% amorphous. So manufacturers are expected to invest in capital to support this and 

have all of their grain-oriented capital sit idle, or severely under-utilized while building non-DOE items 

only. If grain-oriented pricing would ever support moving back to grain-oriented, then the amorphous 
capital would sit idle. Raise your hand if you want to sign up for that business model. It is certainly not 

very attractive and may present challenges for manufacturers selling to their top management.

Best Regards,

Aaron

From: Hirsch, Bruce R [mailto:Bruce.R.Hirsch@bge.com] 

Sent: Wednesday, November 16, 2011 11:09 AM 

To: 'Jerry Hodge'; Steve Nadel; Robert Berman; John Caskey 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; mhyland@appanet.org; 

Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; tpetrosino@carolina.rr.com; 

dbrender@cda.copper.org; James.Lass@cleco.com; chris.brown@cogentpowerinc.com; 

frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; Meyers, Aaron; Trujillo, Antonio; 

Moore, Jack C; Corkran, Jerry L; tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; 

Emily (CONTR) Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; srosenstock@eei.org; 

DYoung@energy-solution.com; rick.anderson@faypwc.com; bsmith@federalpacific.com; 

rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; greg.coulter405@gmail.com; 

ned.efbrush@gmail.com; Richard Parker; Paul.Ryan@hitmet.com; Daniel Cohen; Phil Hopkinson; 

cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; dave.millure@metglas.com; 

kwinder@mleainc.com; jrossetti@mlgw.org; brian.coffey@navigant.com; caitlin.johnson@navigant.com; 

matthew.nardotti@navigant.com; mrivest@navigant.com; zhimei.luo@navigant.com; Jim Creevy; 

mwaltner@nrdc.org; rroy@nrdc.org; robert.saint@nreca.coop; Teckman@nwcouncil.org; 

vijay.tendulkar@onyxpower.com; gbf1@pge.com; chuck.simmons@pgnmail.com; ahofmann@publicpower.org; 

pkumar@publicpower.org; adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference 

 

Jerry,

I agree with you. While I support seeing the amorphous suppliers get an opportunity to participate more in 

the market, I would like to see their share grow gradually and be driven by competition. To reward 

them a large share of the market on day 1 would, in my perspective, create pandemonium in the Industry - 

and not just with the steel suppliers but also in the transformer manufacturing part of the process. This 

sounds more and more like a phased in approach is appropriate but I believe we were told we cannot 

consider that. 

 Bruce
From: Jerry Hodge [mailto:jhodge@howard-ind.com] 

Sent: Wednesday, November 16, 2011 10:23 AM 

To: Steve Nadel; Hirsch, Bruce R; Robert Berman; John Caskey 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; mhyland@appanet.org; 

Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; tpetrosino@carolina.rr.com; 

dbrender@cda.copper.org; James.Lass@cleco.com; chris.brown@cogentpowerinc.com; 

frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; Aaron Meyers; Antonio Trujillo; Jack 

C Moore; Jerry L Corkran; tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily 

(CONTR) Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; srosenstock@eei.org; 

DYoung@energy-solution.com; rick.anderson@faypwc.com; bsmith@federalpacific.com; 

rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; greg.coulter405@gmail.com; 

ned.efbrush@gmail.com; Richard Parker; Paul.Ryan@hitmet.com; Daniel Cohen; Phil Hopkinson; 

cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; dave.millure@metglas.com; 

kwinder@mleainc.com; jrossetti@mlgw.org; brian.coffey@navigant.com; caitlin.johnson@navigant.com; 

matthew.nardotti@navigant.com; mrivest@navigant.com; zhimei.luo@navigant.com; Jim Creevy; 

mwaltner@nrdc.org; rroy@nrdc.org; robert.saint@nreca.coop; Teckman@nwcouncil.org; 

vijay.tendulkar@onyxpower.com; gbf1@pge.com; chuck.simmons@pgnmail.com; ahofmann@publicpower.org; 

pkumar@publicpower.org; adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference

 

To Richard, Steve, Bruce, Phil, Robert & John and All: 

 

One of our biggest concerns as we try to go further up the Efficiency Curve is material 

availability. If we are not real careful, we may upset the critical balance of core materials to the 

point where there could be a shortage of transformers. As we go to higher EL's, amorphous 

requirements will take off, possibly by 10 fold. It takes a good amount of effort and capital to 

achieve these new levels on a consistent basis, there will definitely be growing pains. 

Transformer manufacturers will have to learn how to deal with this .001" thick material. They 

too, will be on a learning curve. 

 

The silicon manufacturers, who have served this industry well for many, many years will see a 

big drop in their demand and will either have to downscale or find new outlets such as exporting 

to sell their products. Their employment could change significantly. 

 

The point I'm trying to make is that our decisions shouldn't be made lightly or we'll possibly put 

the transformer and utility industries in a state of turmoil that might take a long time to correct. 

 
The charts & data presented so far seem to suggest that the crossover point is somewhere near 

EL-1.5. I would like to recommend that we look at an EL-1.5 for 95 KV BIL & below units, use 

EL-1 for 125 & 150 KV BIL units and leave the 200 KV BIL units as they exist today. 

 

I think this would help keep all the core iron players in the game, it should allow the amorphous 

metal industry to grow and it will provide a reasonable and common sense approach to providing 

highly efficient transformers for the utility industry. 

 

Just a suggestion; 

 

Jerry 

 

Jerry Hodge 

Consulting Engineer, E.E., M.S., P.E. 

Retired V.P. & G.M. of Pole Type Transformer & Regulator Div. 

Howard Industries Inc. 

P.O.Box 1588 

Laurel, Ms, 39440 

601 422-1539 Bus. 

484 226-6190 Cell 

CONFIDENTIALITY NOTICE: The information in this e-mail message, including all replies or forwarded messages connected herewith, is 

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-----Original Message----- 

From: Steve Nadel [mailto:snadel@aceee.org] 

Sent: Tuesday, November 15, 2011 5:51 PM 

To: Bruce R Hirsch; Robert Berman; John Caskey 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; mhyland@appanet.org; 

Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; tpetrosino@carolina.rr.com; 

dbrender@cda.copper.org; James.Lass@cleco.com; chris.brown@cogentpowerinc.com; 

frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; Aaron Meyers; Antonio Trujillo; Jack 

C Moore; Jerry L Corkran; tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily 

(CONTR) Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; srosenstock@eei.org; 

DYoung@energy-solution.com; rick.anderson@faypwc.com; bsmith@federalpacific.com; 
rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; greg.coulter405@gmail.com; 

ned.efbrush@gmail.com; Richard Parker; Paul.Ryan@hitmet.com; Jerry Hodge; Daniel Cohen; Phil Hopkinson; 

cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; dave.millure@metglas.com; 

kwinder@mleainc.com; jrossetti@mlgw.org; brian.coffey@navigant.com; caitlin.johnson@navigant.com; 

matthew.nardotti@navigant.com; mrivest@navigant.com; zhimei.luo@navigant.com; Jim Creevy; 

mwaltner@nrdc.org; rroy@nrdc.org; robert.saint@nreca.coop; Teckman@nwcouncil.org; 

vijay.tendulkar@onyxpower.com; gbf1@pge.com; chuck.simmons@pgnmail.com; ahofmann@publicpower.org; 

pkumar@publicpower.org; adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference

Bruce, 

 

Our sense is that at EL1, M3 will dominate. We're looking to go farther up the curve. 

The group agreed to have DOE calculate $/W because some people wanted that info because 

that's a metric they are used to. $/kW is not a decision criteria for us, nor do I expect it to be one 

for DOE. Decisions need to be made on the full life-cycle cost analysis and not simple metrics, 

be they $/kW or even $/kWh. 

 

Steve 

>>> "Hirsch, Bruce R" <Bruce.R.Hirsch@bge.com> 11/15/2011 12:30 PM >>> 

Steve,

From a user standpoint, I agree that having a competitive market (between M3 and amorphous) is 

desirable. From all the testimony I have heard, this comes at the EL1 level. Even Wes said that the 

changeover is between the EL1 and EL2 levels so going to EL2 sways the usage to amorphous. ---And I 

understand ABB can meet EL3 and EL4 with M3 but it is not competitive. 

I thought we had agreed to look at the cost from a $/watt basis. If not then we need to determine what the 

comparison value should be. It appears you have suggested it should be $/kWh. I guess I am interested in 

what others think of using $/kWh.

 Bruce 
From: Steve Nadel [mailto:snadel@aceee.org] 

Sent: Tuesday, November 15, 2011 8:58 AM 

To: Hirsch, Bruce R; Robert Berman; John Caskey 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; mhyland@appanet.org; 

Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; tpetrosino@carolina.rr.com; 

dbrender@cda.copper.org; James.Lass@cleco.com; chris.brown@cogentpowerinc.com; 

frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; Aaron Meyers; Antonio Trujillo; Jack 

C Moore; Jerry L Corkran; tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily 

(CONTR) Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; srosenstock@eei.org; 

DYoung@energy-solution.com; rick.anderson@faypwc.com; bsmith@federalpacific.com; 

rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; greg.coulter405@gmail.com; 

ned.efbrush@gmail.com; Richard Parker; Paul.Ryan@hitmet.com; jhodge@howard.com; Daniel Cohen; Phil 

Hopkinson; cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; 

dave.millure@metglas.com; kwinder@mleainc.com; jrossetti@mlgw.org; brian.coffey@navigant.com; 

caitlin.johnson@navigant.com; matthew.nardotti@navigant.com; mrivest@navigant.com; 

zhimei.luo@navigant.com; Jim Creevy; mwaltner@nrdc.org; rroy@nrdc.org; robert.saint@nreca.coop; 

Teckman@nwcouncil.org; vijay.tendulkar@onyxpower.com; gbf1@pge.com; chuck.simmons@pgnmail.com; 

ahofmann@publicpower.org; pkumar@publicpower.org; adelaski@standardsASAP.org; 

jmauer@standardsasap.org; wes.patterson@us.abb.com; chad.kennedy@us.schneider-electric.com; 

thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference

 

Two comments. First, some comments have focused on just the market for M3 and amorphous steel. The two 

markets are linked -- we need competition between the two to keep the price of both in check. We don't want a 

standard that strongly favors one over the other. The revised DOE analysis on the mix between M3 and amorphous 

at different standard levels should help us to address this. Second, reducing transformer losses primarily affects 

baseload, not peak. So talking about cost per kW is misleading. An efficient transformer is energized for more than 

8000 hours per year. The average DSM measure saves for about 3000 hours per year (although there is wide 

variation). If you want to compare, you'd need to compare levelized cost per kWh saved over the measure lifetime.

Steve 

>>> "Hirsch, Bruce R" <Bruce.R.Hirsch@bge.com> 11/15/2011 7:37 AM >>>

John’s points are well taken. Keep in mind that the DOE numbers indicate a payback at EL4 only if 

amorphous steel is used. Thus, to assume that because it can be built using M3 steel, all is well, is totally 

untrue. In John’s auto analogy, at least the customer has a choice of spending the extra money. In our 

case, the customer will have no choice.

We all also need to understand that there is not an infinite supply of money to spend on efficiency 

improvements. By forcing utilities to spend money on improving transformer efficiencies, we may very 

well be taking money out of other efficiency programs which have a much higher payback than what is 

being proposed here. In BGE’s case our package of efficiency programs cost us approximately $139 per 

kilowatt saved. What is being proposed here is up to 100 times more costly. If BGE pulls back funds from 

other efficiency programs to pay the high costs for transformer efficiencies, we would see a significant 

decline in efficiency improvements overall. 
 

 Bruce

 

From: Caskey, John [mailto:Joh_Caskey@nema.org] 

Sent: Monday, November 14, 2011 3:14 PM 

To: Robert Berman; Hirsch, Bruce R 

Cc: 'Steve Nadel'; Phil Hopkinson; Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; 

mhyland@appanet.org; Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; 

tpetrosino@carolina.rr.com; dbrender@cda.copper.org; James.Lass@cleco.com; 

chris.brown@cogentpowerinc.com; frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; 

Aaron Meyers; Antonio Trujillo; Jack C Moore; Jerry L Corkran; tballo@earthjustice.org; 

carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily (CONTR) Marchetti; Jeremiah (CONTR) Freeman; 

Jim Raba; John Cymbalsky; srosenstock@eei.org; DYoung@energy-solution.com; rick.anderson@faypwc.com; 

bsmith@federalpacific.com; rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; 

greg.coulter405@gmail.com; ned.efbrush@gmail.com; Richard Parker; Paul.Ryan@hitmet.com; 

jhodge@howard.com; Daniel Cohen; cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; 

ScottB@LVMetals.com; dave.millure@metglas.com; kwinder@mleainc.com; jrossetti@mlgw.org; 

brian.coffey@navigant.com; caitlin.johnson@navigant.com; matthew.nardotti@navigant.com; 

mrivest@navigant.com; zhimei.luo@navigant.com; Creevy, Jim; mwaltner@nrdc.org; rroy@nrdc.org; 

robert.saint@nreca.coop; Teckman@nwcouncil.org; vijay.tendulkar@onyxpower.com; gbf1@pge.com; 

chuck.simmons@pgnmail.com; ahofmann@publicpower.org; pkumar@publicpower.org; 

adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference

 

Robert

You continue to reference the ABB data presented by Wes Patterson as indicating that since a transformer 

was sold at the EL3 or EL4 efficiency level that this level is cost effective. Specifically, you state “Market 

sales data, however, is quite real. In this case it unambiguously says that the transformers at EL4 are an 

economically reasonable choice -- the market has, in fact, selected that choice on multiple occasions”. 

This is simply NOT TRUE. 

Just because a person buys as Jaguar for $100k that gets 25 mpg in place of a $40k Cadillac that gets 20 

mpg; does NOT mean that the $60k delta will ever be “economically reasonable” for the extra 5 mpg. 

You seem to be assuming that all of the transformers purchased from ABB that meet the efficiency levels 

were purchased for efficiency reasons. This is simply not fact. The fact is that one large transformer 

manufacturer was able to produce distribution transformers at EL3 and EL4 using M3 steel. To my 

knowledge, Wes did not state the price for these transformers. In addition, just because one company can 
produce this product doesn’t mean that all transformer manufacturers can make this product at this level 

using M3 steel.

My hope is that we can all understand the facts and the analysis results better over the next few weeks so 

that we can negotiate a solution that benefits the consumers, the ratepayers, the manufacturers, the 

environment, etc. I plan to stay at the table till the end of the negotiation process. 

Regards,

John 

John F. Caskey, CEM

Assistant Vice President, Industry Operations

National Electrical Manufacturers Assoc. (NEMA)

1300 North 17th Street - Suite 1752 

Rosslyn, VA 22209

john.caskey@nema.org

703-841-3233 Voice

703-841-3333 FAX

703-350-6886 Cell

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

Sent: Monday, November 14, 2011 1:19 PM 

To: Hirsch, Bruce R 

Cc: 'Steve Nadel'; Robert Berman; Phil Hopkinson; Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine 

(EMAB) Savitz; mhyland@appanet.org; Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; 

tpetrosino@carolina.rr.com; dbrender@cda.copper.org; James.Lass@cleco.com; 

chris.brown@cogentpowerinc.com; frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; 

Aaron Meyers; Antonio Trujillo; Jack C Moore; Jerry L Corkran; tballo@earthjustice.org; 

carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily (CONTR) Marchetti; Jeremiah (CONTR) Freeman; 

Jim Raba; John Cymbalsky; srosenstock@eei.org; DYoung@energy-solution.com; rick.anderson@faypwc.com; 

bsmith@federalpacific.com; rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; 

greg.coulter405@gmail.com; ned.efbrush@gmail.com; Richard Parker; Paul.Ryan@hitmet.com; 

jhodge@howard.com; Daniel Cohen; cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; 

ScottB@LVMetals.com; dave.millure@metglas.com; kwinder@mleainc.com; jrossetti@mlgw.org; 
brian.coffey@navigant.com; caitlin.johnson@navigant.com; matthew.nardotti@navigant.com; 

mrivest@navigant.com; zhimei.luo@navigant.com; Creevy, Jim; Caskey, John; mwaltner@nrdc.org; 

rroy@nrdc.org; robert.saint@nreca.coop; Teckman@nwcouncil.org; vijay.tendulkar@onyxpower.com; 

gbf1@pge.com; chuck.simmons@pgnmail.com; ahofmann@publicpower.org; pkumar@publicpower.org; 

adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: Re: Negotiated Rulemaking - Distribution Transformers Teleconference

 

Bruce, 

 

Those upfront transformer costs are compared to the fuel cost savings in the LCC approach. The 

discounting process values fuel cost saving in the future at less than the costs incurred today. The 

positive LCC means that that the efficiency advocates are not ignoring costs, but comparing 

them with benefits and finding that the consumer is better off and will be paying less. One does 

not, however, need to rely on the LBL analysis to see this. The ABB sales data shows M3 

transformers being delivered at EL4 efficiency. As a modeler, I am always skeptical of model 

results -- people do not live in computers and certainly not on in some of the back-of-theenvelope calculations that we have seen from others. Market sales data, however, is quite real. In 

this case it unambiguously says that the transformers at EL4 are an economically reasonable 

choice -- the market has, in fact, selected that choice on multiple occasions. 

 

To the extent that there are dug-in positions, again the evidence does not support that it is the 

efficiency advocates that are dug-in. Although EL4 is achievable and beneficial based both on 

market data and LBL analyses, the proponents of greater efficiency indicated a willingness to 

 compromise. It is certain representatives of the industry who have consistently said either no 

change, or a fractional change. It is those industry representatives who appear to be advancing 

the "my position or nothing" attitude. Although I happen to agree that substantial movement 

towards more efficient distribution systems, I also note that these are incredibly expensive 

meetings. We have a large number of very senior people devoting substantial time to the 

meetings, their preparation and non-trivial travel costs. These people have other things 

competing for their time. If you and others honestly believe that you cannot agree to a higher 

standard, and place no value on regulatory certainty, then let's not waste additional time and 

money. Let's just say that we gave it a good shot, cut our losses here, and make our respective 

cases to DOE outside the negotiation process and let DOE make it's own decision. I believe that 

they certainly have sufficient information to support their position in a February NOPR. I can't 

imagine what else they would need. 

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 Nov 14, 2011, at 11:49 AM, Hirsch, Bruce R wrote: 

Steve,

I am disappointed with your approach to this assignment.

It appears that negotiation to you is defined as agreeing with your position --- or calling it off. It is 

unfortunate that you believe the American public, especially in these trying economic times, should be 

expected to foot the (very large) bill for more efficient transformers when it is still not certain that there is 

value in doing so. You have clung to one suspect calculation that indicates there may be a payback --- in 

the distant future --- and only if all the assumptions being made pan out. You choose to ignore the costs, 

not yet factored in, on US jobs, US businesses and the reliability of supply of an item so desperately 

needed for our economy to expand.

This is not a “cut and dried” economic decision but is one that needs to be taken seriously for the major 

impact it could have on the electric supply of the US and the financial position of the American public. If 

DOE makes the final decision on this, I would expect them to do “due diligence” in considering all the 

effects there decision would have on US businesses and the US economy. 

Let it be known that the Utility Industry has not pulled out of the negotiation process and will continue to 

work with DOE to reach the right decision.

Bruce. 
From: Steve Nadel [mailto:snadel@aceee.org] 

Sent: Friday, November 11, 2011 2:16 PM 

To: Robert Berman; Phil Hopkinson 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) 

Savitz; mhyland@appanet.org; Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; Hirsch, Bruce 

R; tpetrosino@carolina.rr.com;dbrender@cda.copper.org; James.Lass@cleco.com; chris.brown@cogentpowerinc.co

m; frank.guilbault@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; Aaron Meyers; Antonio Trujillo; 

Jack C Moore; Jerry L Corkran; tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; 

Emily (CONTR) Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John 

Cymbalsky; srosenstock@eei.org; DYoung@energysolution.com; rick.anderson@faypwc.com; bsmith@federalpacific.com; rgreeson@federalpacific.com; carlos.gayta

n@ge.com; artrosenfeld@gmail.com; greg.coulter405@gmail.com; ned.efbrush@gmail.com; Richard 

Parker; Paul.Ryan@hitmet.com; jhodge@howard.com; Daniel 

Cohen; cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; dave.millure@metg

las.com; kwinder@mleainc.com;jrossetti@mlgw.org; brian.coffey@navigant.com; caitlin.johnson@navigant.com; 

matthew.nardotti@navigant.com; mrivest@navigant.com; zhimei.luo@navigant.com; Jim.creevy@nema.org; john.c

askey@nema.org;mwaltner@nrdc.org; rroy@nrdc.org; robert.saint@nreca.coop; Teckman@nwcouncil.org; vijay.te

ndulkar@onyxpower.com; gbf1@pge.com; chuck.simmons@pgnmail.com; ahofmann@publicpower.org;pkumar@

publicpower.org; adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; chad.kenn

edy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference

 

Phil,

We're in the middle of negotiations and some of us have made clear that no or little change to the standard is not 

acceptable as the DOE analysis justifies higher standards (higher levels are technically feasible and cost-effective on 

a life-cycle cost basis). The efficiency groups would rather leave the decision to DOE than agree to subpar 

standards. If you and other participants want to veto any significant change in the standard, then we might as well 

save some time, break off negotiations and just make our respective arguments to DOE. Is that what you want to 

do? If the answer is no, then let's start talking about how to make higher standards acceptable rather than continue 

to make arguments about why low standards are needed. We're all busy and if we're going to make progress we 

need to break new ground and not rehash old ground.

Steve 

>>> Phil Hopkinson <phopkinson@hvolt.com> 11/11/2011 1:16 PM >>>

Hello Robert and all:

You must not have looked at Jerry Corkran’s message because he found the cost to be $17/watt, which is 

pretty close to my number, where both Jerry and I have used M3 core steel to derive the cost curve. The 

fact is that the cost curve is very steep with M3 and quickly hits the brick wall.
1. I have checked Carlos Gaytan’s cost curves as well and he is finding about the same relationship 

with M3.

2. I have checked Wes Patterson’s data as well and he is finding an M3 cost curve about the same as 

mine.

3. I have checked the OPS data with M3 as well and it too is very close to $20/watt.

a. For example, for design line 1 they show an efficiency at 50% load of 99.08% which translates to 

232 watts of loss and sells for $1,960.73.

b. They show another M3 design with an efficiency of 99.26% which translates to 186 watts of loss and 

sells for $2962.11.

c. The change in selling price is $2,962.11-$1,906.11 or +$1,001.38

d. The change in watts is 232-186 or -46 watts.

e. The OPS $/watt is therefore, $1,001.38/46 watts or $21.77

f. Hence we see that all data sources are pointing to cost per watt of ~$20 /watt saved to go from the 

current mandatory standard to EL1. I get $30/watt to go to EL2 and $53/watt to go to EL3

4. The fact is that M3 is about out of gas and the DOE did a good job in the last rule making.

5. The fact also is that a push to anything beyond present does not show economic value and I do not 

support it.

6. The fact also is that a push to higher efficiencies will kill the new transformer market and open up the 

rebuild market, destroying jobs at the new transformer manufacturers and resulting in transformers of 

lower efficiency which will cost energy and not save it.

Best regards,

Phil

Philip J Hopkinson, PE 

President & CEO HVOLT Inc. 

3704 High Ridge Rd. 

Charlotte, NC 28270 

phopkinson@hvolt.com

Ph 704-846-3290

Fx 704-845-2520
Cell 704-236-3320

www.hvolt.com

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

Sent: Friday, November 11, 2011 11:16 AM 

To: Phil Hopkinson 

Cc: Corkran, Jerry L; Richard Parker; Freeman, Jeremiah 

(CONTR); rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@LVMetals.com; john.caskey@nema.org; 

Cymbalsky, 

John; adelaski@standardsASAP.org;Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@f

ederalpacific.com; bruce.r.hirsch@bge.com; jhodge@howard.com; mhyland@appanet.org; dave.millure@metglas.c

om; snadel@aceee.org;wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.Polinski@ATImetals.co

m; artrosenfeld@gmail.com; srosenstock@eei.org; rroy@nrdc.org; robert.saint@nreca.coop; chuck.simmons@pgn

mail.com;kwinder@mleainc.com; mwaltner@nrdc.org; jerry.schoen@aksteel.com; Paul.Ryan@hitmet.com; ahofma

nn@publicpower.org; pkumar@publicpower.org; bsmith@federalpacific.com; greg.coulter405@gmail.com;jmauer

@standardsasap.org; Cohen, Daniel; Meyers, 

Aaron; Jim.creevy@nema.org; jrossetti@mlgw.org; cabolduc@lbl.gov; kcoughlin@lbl.gov; brian.coffey@navigant.

com; mrivest@navigant.com; gjrosenquist@lbl.gov;caitlin.johnson@navigant.com; zhimei.luo@navigant.com; 

Marchetti, Emily (CONTR); charlied@uus.org; DYoung@energysolution.com; James.Lass@cleco.com; maheshsampat@bellsouth.net;matthew.nardotti@navigant.com; Raba, Jim; 

Savitz, Maxine 

(EMAB); tpetrosino@carolina.rr.com; chris.brown@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; fra

nk.guilbault@cogentpowerinc.com;ned.efbrush@gmail.com; dbrender@cda.copper.org; chad.kennedy@us.schneide

r-electric.com; eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; thomas.patzner@us.schneiderelectric.com;carlosgsiqueiros@eaton.com; Robert Berman; Trujillo, Antonio; Moore, Jack C 

Subject: Re: Negotiated Rulemaking - Distribution Transformers Teleconference

 

Even if it were that high (and Mr. Hopkinson is the only one I've seen who has put the number 

anywhere near that), the efficiency objective is saving Watt-hours (energy) not Watts (the 

capacity to save energy) . One Watt saved for 8,760 hours per year for 30 years is 262.8 kWh 

(not counting leap years). Even at Mr. Hutchinson's $20, that's just over 7¢ / kWh. If Mr. 

Hutchinson will examine his electric bill, as he has reported, he will see that even as high as 7¢ 

it's a good buy, and that assumes we put a ZERO value on any environmental benefits (which is 

why DOE agreed to reconsider its 2007 MEPS in the first place. 

 

Indeed, the cost of losses per Watt (roughly the A factors that OPS has been using) are no where 

near the $20 claimed here. Moreover, as ABB and others have pointed out, the proper approach 

would have been to minimize cost subject to efficiency, not A & B, which would have resulted 

in a lower, flatter curve to the asymptote. ABB's actual market data -- physical transformers 

produced and delivered -- shows a competitive market for M3 transformers even at EL4 

efficiency. You can make all the hypothetical claims you want to, gentlemen, the market is 

the real world. 
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 Nov 10, 2011, at 6:53 PM, Phil Hopkinson wrote: 

 

Well stated Jerry 

 

That is also what my analysis and report said. If you restrict to M3 then the cost of EL1 rises to 

about $20/watt. 

 

Phil 

Phil Hopkinson,P.E. 

HVolt Inc. 

704-846-3290

F: 704-845-2520

C: 704-236-3320

phopkinson@hvolt.com

On Nov 10, 2011, at 18:04, "Corkran, Jerry L" <Jerry.Corkran@CooperIndustries.com> wrote: 

To Mr. Parker and the DOE working group,
The reason for the request for the incremental cost of the losses is that the current DOE efficiency levels 

can be obtained if the design is optimized at about $4 per core watt and $1 per winding watt at full load. 

At the DOE 50% kVA rating, this is the same as evaluating the losses or optimizing the design at about 

$4 per total watts loss. 

The present DOE efficiency loss level results in transformer designs about like many utilities were 

purchasing their transformers before 2007. The utilities were purchasing the efficiency levels that were 

justified based on the cost of losses. A few utilities were purchasing higher efficiency that the 2007 

efficiency rules because of the calculated cost of energy being higher than the $4/$1 loss evaluation. 

What came up in the discussion last week was even for loss level 1, the incremental cost of losses was 

about $17 per watt for the design checked, between the present DOE losses an efficiency level of DEL1. 

The added cost of $17 per watt is so much higher than the typical cost of the energy for the utilities, that 

it is very questionable that the DOE payback estimates are accurate. A 3% interest rate may be a factor in 

the payback calculations.

Jerry Corkran

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

Sent: Thursday, November 10, 2011 3:23 PM 

To: Robert Berman 

Cc: Freeman, Jeremiah 

(CONTR); rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@LVMetals.com; john.caskey@nema.org; 

Corkran, Jerry L; Cymbalsky, 

John; adelaski@standardsASAP.org;Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@f

ederalpacific.com; bruce.r.hirsch@bge.com; jhodge@howard.com; mhyland@appanet.org; dave.millure@metglas.c

om;snadel@aceee.org; wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.Polinski@ATImetals.co

m; artrosenfeld@gmail.com; srosenstock@eei.org; rroy@nrdc.org; robert.saint@nreca.coop;chuck.simmons@pgnm

ail.com; kwinder@mleainc.com; mwaltner@nrdc.org; jerry.schoen@aksteel.com; Paul.Ryan@hitmet.com; ahofman

n@publicpower.org; pkumar@publicpower.org;bsmith@federalpacific.com; greg.coulter405@gmail.com; jmauer@

standardsasap.org; Cohen, Daniel; Meyers, 

Aaron; Jim.creevy@nema.org; jrossetti@mlgw.org; cabolduc@lbl.gov; kcoughlin@lbl.gov;brian.coffey@navigant.

com; mrivest@navigant.com; gjrosenquist@lbl.gov; caitlin.johnson@navigant.com; zhimei.luo@navigant.com; 

Marchetti, Emily (CONTR); charlied@uus.org; DYoung@energysolution.com; James.Lass@cleco.com; maheshsampat@bellsouth.net; phopkinson@hvolt.com; matthew.nardotti@n

avigant.com; Raba, Jim; Savitz, Maxine 

(EMAB); tpetrosino@carolina.rr.com;chris.brown@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; fran
k.guilbault@cogentpowerinc.com; ned.efbrush@gmail.com; dbrender@cda.copper.org; chad.kennedy@us.schneide

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

Subject: Re: Negotiated Rulemaking - Distribution Transformers Teleconference

 

Robert, 

I understand the DOE staff are working on the incremental Watts calculations and will get that 

out to group as soon as it's ready. 

best wishes, 

Richard 

On Thu, Nov 10, 2011 at 11:52 AM, Robert Berman <bermaneconomics@gmail.com> wrote: 

Thank you Richard. That clarification is helpful. 

 

In the liquid-filled meeting we were told that we would receive an analysis of incremental Watts 

saved by DL for all ELs, as well as the incremental cost. When will that analysis be available? 

For many of us, that analysis is the basis for additional, perhaps extensive analyses, so it should 

come with enough lead time before any additional meetings or teleconferences to that we can 

give it the required consideration. It would be most helpful if the incremental cost were provided 

separately for transformer and installation, with any pole component of the installation identified. 

 

For the MV Dry and LV Dry meetings, it would be most helpful if you would also circulate an 

agenda with objectives, hopefully this week, so that we are able to prepare for those meetings. 

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 Nov 10, 2011, at 11:14 AM, Richard Parker wrote: 

Dear Colleagues: 

The telcon on the 17th is currently planned for medium-voltage dry-type and the telcon on the 

21st is reserved for low-voltage. There will be revised analysis circulated in advance of both 

calls per our discussion yesterday. Each call has substantial chunks of time allocated, though I 

hope we won't need all that time. 

It may be prudent to schedule a liquid-filled call at some point as well, but I propose that we 

hold off on that for day or so, until we can clarify when revised analysis for liquid-filled will be 

ready. 

Thanks for your very constructive participation in the meetings over the last two days. 

Richard Parker 

On Thu, Nov 10, 2011 at 10:05 AM, Freeman, Jeremiah (CONTR) 

<Jeremiah.Freeman@ee.doe.gov> wrote: 

When: Thursday, November 17, 2011 1:00 PM-5:00 PM (GMT-05:00) Eastern Time (US & Canada).

Where: Webinar and Phone

Note: The GMT offset above does not reflect daylight saving time adjustments.

*~*~*~*~*~*~*~*~*~*

Dear Colleagues,

This event is to save the time slot on your calendar based on our discussion at yesterday's meeting. Later 

today further information will be sent regarding the registration information for our November 17 and 

November 21 webinars. After registering you will get the link for the webinar and a toll free number.

Please call with questions or concerns.
Very Respectfully,

Jeremiah Freeman

202-431-4243 (cell)

202-586-1867 (office)

 

 

 

 

>>> This e-mail and any attachments are confidential, may contain legal, 

professional or other privileged information, and are intended solely for the 

addressee. If you are not the intended recipient, do not use the information 

in this e-mail in any way, delete this e-mail and notify the sender. CEG-IP2