From: Bob Smith [mailto:bsmith@federalpacific.com]

Sent: Tuesday, December 13, 2011 3:07 PM

To: 'Katie Coughlin'; 'Corkran, Jerry L'

Cc: Eric.Petersen@aksteel.com; 'Richard Parker'; 'Ale x Hofmann'; 'Andrew Delaski'; Aris Marantan; 'Art

Rosenfeld'; 'Bob Saint'; 'Brenda Edwards'; Brian Coff ey; Caitlin Johnson; 'Carlos Gaytan'; 'Caskey, John';

'Charlie Drexler'; 'Charlie Stevens'; 'Chris Bolduc'; 'C hris Brown'; 'Clark Silcox'; 'Creevy, Jim'; 'Dan Cohen';

'Daniel Young'; 'David Flaten'; 'Emily Marchetti'; 'F reeman, Jeremiah'; 'Gary Fernstrom'; 'Greg Coulter';

'Greg Rosenquist'; 'Hirsch, Bruce R'; 'James Lass'; 'Jennifer Tiedeman'; 'J erry Hodge'; 'Jerry Schoen'; 'Jim

Raba'; 'Joanna Mauer'; 'John Cymbalsky'; 'John Rosse tti'; 'Ken Winder'; 'Mahesh P. Sampat'; Matthew

Nardotti; 'Maxine Savitz'; 'Meg Waltner'; 'Meyers, Aaron' ; 'Michael Hyland'; Michael Rivest; 'Millure, Dave';

Pamela Costello; 'Phil Harter'; 'Ph il Hopkinson'; 'Polinski, Raymond'; 'P uesh Kumar'; 'Rick Anderson'; 'Rob

Greeson'; 'Robert Berman'; 'Robert van Buskirk'; 'Robin Roy'; 'Ryan, Paul'; 'Scott Beck'; 'Simmons, Chuck';

'Steve Nadel'; 'Steve Rosenstock'; 'Ted Johnstone'; 'Thomas Petrosino'; 'Tim Ballo'; 'Tom Eckman'; 'Wes

Patterson'; Zhimei Luo; 'Trujillo, Antonio'

Subject: RE: NES savings in NIA: "relative to a base-case scenario of no standard"

Dear Katie:

The electric utilities use peak loading in their calculations for the “B” factor. Associated with the peak

loading values is a parameter called “ Loss Factor ”, which is a time concept, that basically says what

portion of the year that the peak load has to be on the transformer, so that the losses incurred at peak

load become equal to the actual losses experienced by the transformer during the same year period.

You also have run across another parameter called the responsibility factor

, which is also a time

concept, which says what is the portion of the time that the transformer’s peak load coincides with the

utility’s system peak. This allows the utility to know how much system capacity is needed when peak

loads occur. RMS Loading is a concept that is really limited in relevance to the issue of knowing how to

adjust the transformer’s efficiency for maximum savings in Kilowatt hours and system capacity.

Your studies based on RMS loading are sending us in a direction that will encourage us to raise

transformer efficiencies and transformer prices to levels that will probably not result in energy savings

or in the postponement of plant construction in an optimized manner.

I wish I could be more supportive of the superb and indefatigable efforts made by LBNL. Yet I have to

rely on the concepts developed over many decades by very intelligent utility engineers and financial

personnel who have implemented sound methods of identifying their costs and improved system

efficiency opportunities.

Regards,

Bob Smith, PE

Product Manager

Federal Pacific

601 Old Airport Road

Bristol, VA 24201

TEL: (276) 645-8836

FAX: (276) 645-8956CELL: (276) 591-6143

Email: bsmith@federalpacific.com

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From: Katie Coughlin [ mailto:kcoughlin@lbl.gov ]

Sent: Tuesday, December 13, 2011 2:05 PM

To: Corkran, Jerry L

Cc: Eric.Petersen@aksteel.com ; Richard Parker; Alex Hofmann; Andrew Delaski; Aris Marantan; Art

Rosenfeld; Bob Saint; Bob Smith; Brenda Edwards; Brian Coffey; Caitlin Johnson; Carlos Gaytan; Caskey,

John; Charlie Drexler; Charlie Stevens; Chris Bolduc; Chris Brown; Clark Silcox; Creevy, Jim; Dan Cohen;

Daniel Young; David Flaten; Emily Marchetti; Freeman, Jeremiah; Gary Fernstrom; Greg Coulter; Greg

Rosenquist; Hirsch, Bruce R; James Lass; Jennife r Tiedeman; Jerry Hodge; Jerry Schoen; Jim Raba;

Joanna Mauer; John Cymbalsky; John Rossetti; Ke n Winder; Mahesh P. Sampat; Matthew Nardotti;

Maxine Savitz; Meg Waltner; Meyers, Aaron; Michael Hyland; Michael Rivest; Millure, Dave; Pam Costello;

Phil Harter; Phil Hopkinson; Polinski, Raymond; Pu esh Kumar; Rick Anderson; Rob Greeson; Robert

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

Rosenstock; Ted Johnstone; Thomas Petrosino; Tim Ballo; Tom Eckman; Wes Patterson; Zhimei Luo;

Trujillo, Antonio

Subject: Re: NES savings in NIA: "relative to a base-case scenario of no standard"



### Hello all,

Load losses are calculated based on the annual av erage of the squared lo ad, i.e. the RMS. The

LCC analysis sums the results from a sample population of 10,000 transformers, each of which is

loaded differently, so we work with a distribution of RMS loadings.

The shape of this distribution is approximately triangular. The shape of the distribution was

developed based on an analysis of hourly building loads for several hundred commercial,

residential and industrial buildings.

The building load data can give us the averag e load is relative to the peak load. For the

transformer analysis we also need to know what is the peak load rela tive to the transformer

capacity. In the LCC, this "peak load fact or" is also chosen from a distribution.

Uncertainty about how transformers are sized relative to their peak loads is handled by defining

an additional parameter that scales the entire RMS load distribution up or down. The value of

### this parameter determines the average RMS load ing, relative to transfor mer capacity, for the

transformer population.

Initially the Department's estimates for the popu lation-average RMS loading were taken from the

previous rulemaking. For the current rulemaking, th e utility reprsentatives on the committee have

provided us with data on transformer loads, pr imarily for single-phase, smaller capacity units

connected to residential loads. Based on th eir input, our current assumptions are:

- for smaller capacity transformers the average RMS is about 32%

- for smaller capacity transformers in low popul ation density areas the average RMS is 25%

These assumptions apply to design lines 1 and 2. Note that these design lines also serve small

commercial and multi-family loads, but we do not have data on average loading for those

customer classes.

For the larger capacity transformers and 3-phase transformers, the loading is currently set to

about 40% population-average RMS. We also do a sensitivity with the RMS load set equal to

50%. We do not currently have data for the larger capacity range.

regards,

Katie

On Tue, Dec 13, 2011 at 8:14 AM, Corkran, Jerry L < Jerry.Corkran@cooperindustries.com >

wrote:

Katie

– Could you explain what is the percentage of rated nameplate load level or levels used in the

payback calculations and is it an RMS or an average loading? Where did the load levels used come

from? Are there references available to support the load levels used?

Thanks,

Jerry Corkran

From: Katie Coughlin [mailto: kcoughlin@lbl.gov ]

Sent: Monday, December 12, 2011 4:04 PM

To: Eric.Petersen@aksteel.com

Cc: Richard Parker; Alex Hofmann; Andrew Delaski; Ar is Marantan; Art Rosenfeld; Bob Saint; Bob Smith;

Brenda Edwards; Brian Coffey; Caitlin Johnson; Carl os Gaytan; Caskey, John; Charlie Drexler; Charlie

Stevens; Chris Bolduc; Chris Brown; Clark Silcox; Cr eevy, Jim; Dan Cohen; Daniel Young; David Flaten;

Emily Marchetti; Freeman, Jeremiah; Gary Fernstrom; Greg Coulter; Greg Rosenquist; Hirsch, Bruce R;

James Lass; Jennifer Tiedeman; Corkran, Jerry L; Je rry Hodge; Jerry Schoen; Jim Raba; Joanna Mauer;

John Cymbalsky; John Rossetti; Ken Winder; Mahesh P. Sampat; Matthew Nardotti; Maxine Savitz; Meg

Waltner; Meyers, Aaron; Michael Hyland; Michael Ri vest; Millure, Dave; Pam Costello; Phil Harter; PhilHopkinson; 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; Ted

Johnstone; Thomas Petrosino; Tim Ballo; Tom Eckman; Wes Patterson; Zhimei Luo

Subject: Re: NES savings in NIA: "relative to a base-case scenario of no standard"



### Hello all,

The "no standard" phrase in the document should more correctly read "no modification to the

2007 standard".

The base case for the national impacts analysis is the EL0 level with the 2007 standard in force.

Sorry for the confusion,

Katie

On Mon, Dec 12, 2011 at 12:19 PM, < Eric.Petersen@aksteel.com > wrote:

Mr Parker,

Please find attached a page from Chapter 10, National Impact Analysis from the

September 2011 analysis that stat es that the NES are "relat ive to a base-case scenario

of no standard." I'm interpreting this as m eaning that the savings calculated are against

the "affected stock", or the transformers that are currently in the field rather than the

savings that are already to be gained as a result of the 2007 ruling, or EL0.

If my interpretation of this is correct, the current NES an alysis is "double counting" the

energy savings which have already been impl emented by the 2007 rule. Since we are

comparing LCC and Payback against EL0, shouldn 't the NES analysis be relative to the

current EL0 standard rather than us ing a scenario of "no standard"?

Regards,

Eric Petersen

Director Customer Technical Services and Research

AK Steel Corporation

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