From: Corkran, Jerry L [mailto:Jerry.Corkran@CooperIndustries.com]

Sent: Tuesday, October 11, 2011 7:46 PM

To: Rosenstock, Steven; Phil Hopkinson; Edwi n Brush; Robert Berman; Meyers, Aaron

Cc: Bob Smith; Caskey, John; Brian Coffey; Alex Hofmann; Andrew Delas ki; Aris Marantan; Art Rosenfeld; Bob Saint; Caitlin Johnson; Carlos Gayt an; 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 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, C huck; Nadel, Steve; Tim Ballo; Tom Eckman; Wes Patterson; Zhimei Luo; rjstahara@centralmoloneyinc.com; Ali Ghafourian; Dave Brender; jay.ballard@schneider-electric.co m; Kenneth.Harden@schneider-electric.com; Tom Patzner; Steve Nizinski; Richard Parker; Marusinec, Richard M; Trujillo, Antonio Subject: RE: Distribution Transformer Loading and other Analyses



### As mentioned before on the plus side, add in the added load for electric plug in cars. This new demand

for power could greatly increase residential loads and change the whole picture.

Jerry Corkran

From: Rosenstock, Steven [ mailto:SRosenstock@eei.org ]

Sent: Tuesday, October 11, 2011 6:21 PM

To: Phil Hopkinson; Edwin Brush; Robert Berman

Cc: Bob Smith; Caskey, John; Brian Coffey; Alex Hofmann; Andrew Delas ki; Aris Marantan; Art Rosenfeld; Bob Saint; Caitlin Johnson; Carlos Gayt an; 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; Ja mes Lass; Jennifer Tiedeman; Corkran, Jerry L; Jerry Hodge; Jerry Schoen; Joanna Mauer; John Cymbalsk y; John Rossetti; Katie Coughlin; Ken Winder; Mahesh P. Sampat; Matt Miller; Matthew Nardotti; Me g 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; Simm ons, Chuck; Nadel, Steve; 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

But you also have to account for the appliance energy efficiency standards, Energy Star Program, and increasingly stringent building codes which will reduce electric usage at the same homes and buildings.

Examples:

1970's refrigerator: about 1700 kWh New refrigerator: about 500 kWh

1980's central air conditioner: about 7.0 - 8.0 SEER

New central air conditioner: 13.0 SEER Energy Star central air conditioner: 14.5+ SEER and 12.0+ EER

1990's residential central heat pump: 6.8 HSPF 2006 and after heat pump: 7.7 HSPF Energy Star heat pump: 8.2 HSPF for split systems (8.0 for package systems)Steve Rosenstock

EEI

-----Original Message----- From: Phil Hopkinson [ mailto:phopkinson@hvolt.com ]

Sent: Tue 10/11/2011 8:36 AM To: Edwin Brush; Robert Berman Cc: Bob Smith; Caskey, John; Brian Coffey; Alex Hofmann; Andrew Delaski; Aris Marantan; Art Rosenfeld; Bob Saint; Caitlin Johnson; Carlos Gaytan; Charlie Drexler; Char lie Stevens; Chris Bolduc; Silcox, Clark; Creevy, Jim; Dan Cohen; Daniel Young; Eric Peterson; Freeman, Jeremi ah; Gary Fernstrom; Greg Coulter; Greg Rosenquist; Hirsch, Bruce R; James Lass; Jennifer Tiedeman; Jerry Co rkran; 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 Rives t; Millure, Dave; Phil Harter; Polinski, Raymond; Puesh Kumar; Rick Anderson; Rob Greeson; Robert van Buskirk; Robin Roy; Ryan, Paul; Scott Beck; Simmons, Chuck; Nadel, Steve; Rosenstock, Steven; 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

Excellent comments Ned:

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 < http://www.hvolt.com/ >

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; Char lie Stevens; Chris Bolduc; Silcox, Clark; Creevy, Jim; Dan Cohen; Daniel Young; Eric Peterson; Freeman, Jeremi ah; Gary Fernstrom; Greg Coulter; Greg Rosenquist; Hirsch, Bruce R; James Lass; Jennifer Tiedeman; Jerry Co rkran; 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 Rives t; 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 AnalysesPhil, 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 year s (one citing of DoE data has over twice the average consumption per household) - consider the current additiona l existing appliances, activities, penetration of central air conditioning, etc., compared to earlier decades.

There are also current in centives and projections for large increases in numbers of electric and rechargeable electric vehicles for the future, as well as trends to time-of-da y 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 lo ad at night - less opportunity to cool from perhaps the heavy daytime load from summer air conditioning, and prob able higher rms load? -- consider the new system loading, not previously existing, from late-night vehicle recharging.

My suggestion is to consider both current and histori cal loading and loading patterns, and FUTURE potential loading patterns.

Then include "right-sizing" for transformers where appli cations 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 resist ance appropriately to achieve higher ov erall transformer energy efficiency.

Future loading for new transformer production may be significantly higher than current loading (while they are inservice for the next decades).

Best regards,

NEDDr. 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 inte nt is to smooth loading patterns - and is not "new" loading such as the cited above electric and rechargeable electric ve hicles 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, an d, 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 transfor mer 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 surprise d to learn that the LV dry load was a low as it was. Couldn't imagine why anyone would deliberately oversize a transf ormer so inefficiently. A near-by engineer simply said "fire codes" and that immediately made sense. I was al so directed to ASHRAE and related K- 12 studies that assessed the likelihood of further falling loads due to increased efforts for energy c onservation, 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 certain ly prepared to hear arguments for doing otherwise; recognizing that they are not the same. What I am unwilling to accept is an argu ment 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 a lternative 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 simp ly the reciprocal of the other, I have no objection if someone is more comfortable having gone to a different school. Some recogn ition of the cost of money, productivity of capital, and business risk is absolutely necessary, whether a hospital or cookie factory. The questio n, then, is th e 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 fundam ental 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 ma y 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, evaluate s 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 situ ation was beautifully illustrated by a conversation I had with the transformer purchasing manage r at a major IOU. I pointed out that the energy savings

associated with the incr emental 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 < http://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 dive rse loading situations. I believe his an alysis 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 ma ny consulting engineers (Fluor, Black & Veatch, Kiewit, Burns & McDonald, O'Neal, CH2MHill, etc.) that are specify ing 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 w ould value greatly your listing of attrib utes 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 an other 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 sa ke 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 < tel:%28276%29%20645-8836 >

FAX: (276) 645-8212 < tel:%28276%29%20645-8212 >

CELL: (276) 591-6143 < tel:%28276%29%20591-6143 >Email: bsmith@federalpacific.com < mailto:bsmith@fed eralpacific.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 Hofm ann; 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 C oughlin; 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; St eve 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@schneider-electric.com ; Kenneth.Harden@schneider-electric.com ; Tom Patzner ( thomas.patzner@us.sc hneider-electric.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 app ear 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 contex t. Attached are my detailed comments.

<Patzner.doc><October 6.doc>