Summary of the Teleconference of the 

Working Group on Low-Voltage Dry-Type Distribution Transformers 

of the Energy Efficiency and Renewable Energy Advisory Committee 

November 21, 2011 

Richard W. Parker, Facilitator 

Note: This teleconference summary has been prepared for the convenience of the Working Group. It 

has not been approved by the Working Group and should not be construed or taken to represent the 

official position of the Working Group or any member as to what transpired on the call. 

 The Working Group on Low-Voltage Dry-Type Distribution Transformers (“LV Group”) held a 

meeting by teleconference at 2:00 pm on Nov. 21, 2011. 

 DOE consultants presented revised Engineering, LCC and NIA Analysis. Call-in participants found 

the analytical results broadly credible and in keeping with their own information (though some 

participants noted that they saw more design options than shown in the scatterplots, at lower cost and 

induction levels). Overall, the participants accepted the Engineering Analysis and LCC as a basis for 

negotiations (with one exception noted below). They also agreed that refurbishment in response to higher 

costs is most likely not a significant concern in this market, though there is some potential for 

refurbishment in the DL 8 market. However, it was thought that very few transformers in these markets 

are replacement transformers. 

 However, one industry participant observed that for smaller transformers in DL7, there is a risk that 

buyers/manufacturers would respond to an increase in prices from higher standards by switching to 

encapsulated designs which are statutorily exempt. This risk was thought to be particularly acute in the 

15 and 30 kVA range, diminishing thereafter. A range of upper bounds for this range were discussed but 

none was agreed at the meeting. 

 The Advocates then presented their proposal, which they indicated was based on the current DOE 

analysis that excluded amorphous and ZDMH steels. They noted that although LV transformers are not 

subject to a court-ordered deadline, they are subject to mandatory “look back” review every 6 years, that 

they are due for review now, and that DOE was therefore prudent in conducting that review now. 

 Looking at the DOE analysis they noted that EL 5 seems to be the cost-justified standards level for 

both DL 7 and DL8, and also yielded the highest NPV. They indicated a willingness to consider a 

differential standard for the lower kVA ranges of DL7 (certainly 15 and 30 kVA) in order to avoid 

possible circumvention problems, but wanted more information on the upper bound of that range. 

 Industry participants noted that beyond the circumvention problem, a major concern is the impact of 

any higher standard on small manufacturers. It was said that a mitering machine costs around $1.5 

million. They also noted that step-lap designs are more feasible at higher kVA and that there are fewer 

small manufacturers in the DL8 (higher kVA) market. 

 Participants agreed to look to the DOE manufacturing analysis to shed light on manufacturing 

impacts of higher standards (and in particular the efficiency level at which capital conversion is required 

to install mitering equipment for each DL). 

 With that the call concluded.