From: John Rossetti [mailto:JRossetti@mlgw.org]

Sent: Friday, September 23, 2011 2:48 PM

To: Bruce R Hirsch; Jerry L Corkran; Steven Rosenstock; RichardParker; 'Jerry

Hodge'; Daniel Cohen

Cc: snadel@aceee.org; Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com;

mhyland@appanet.org; Raymond.Polinski@atimetals.com; Aaron Meyers; Antonio

Trujillo; Jack C Moore; Jeffrey A Schneider; Jennifer Smith; Michael T Loomans;

Raymond L Poole; Richard M Mar usinec; tballo@earthjustice.org;

carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; John Cymbalsky;

rick.anderson@faypwc.com; bsmith@federalpacific.com; rgreeson@federalpacific.com;

carlos.gaytan@ge.com; BermanEconomics@gmail.com; greg.coulter405@gmail.com;

Paul.Ryan@hitmet.com; Phil Hopkinson; cabolduc@lbl.gov; gjrosenquist@lbl.gov;

kcoughlin@lbl.gov; ScottB@lvmetals.com; dave.millure@metglas.com;

kwinder@mleainc.com; Brian Coffey; Caitlin Johnson; Michael Rivest;

Jim.creevy@nema.org; john.caskey@nema.org; 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; mark.stoering@xcelenergy.com

Subject: Proposed efficiency standards

To all,

In rega rds to the comments submitted below from Jerry Hodge concerning the use of

a total ownership cost (TOC) or evaluated cost (E.C.). The following is an

excerpt taken from Memphis Light Gas and Water Division's October 2009 bid on

Distribution transformers as follows:

Evaluation of Proposals

In addition to th e required minimum D.O.E. efficiency standards this proposal’s

evaluation will include, but not be limited to, a capitalized expense type

estimate of the evaluated cost for transformers as follows:

Pole Type Items (1

‐ 7 & 30

‐ 36), Single

‐ Phase Pad Items (1

‐ 12), and Two

‐ Phase Pad

Items (41

‐ 42)

"A" "B"

E.C.

= I.C

. + $4.00 PNL + $1.27 PLL

Pole Type Items (8

‐ 29 & 37

‐ 72) and Three

‐ Phase Pad Items (1

‐ 40)

"A" "B"

E.C.

= I.C. + $4.04 PNL + $1.41 PLL

Where E.C.

= Evaluated cost in dollars

I.C.

= Initial cost in doll ars

PNL

= No load loss in watts

PLL

= Load loss in watts (Load at Rated Nameplate kVA)

The ranking of all items will be evaluated utilizing best total owning cost that

meets the required D.O.E. efficiency mandate. Loss values quoted will be

considered as guaranteed losses and subject to tol erances and interpretation as

set forth in the latest edition of IEEE C57.12.00.This would fit the recommendation and intent outlined below whereby the end

user's transformer would be optimize to meet the DOE threshold efficiency and at

the same time result in a TOC that would still meet a DOE threshold.

In terms of efficiency the evaluated 50 kVA Single

‐ phase pad

‐ mount tra nsformer

(13200 volt 125 kV BIL), chosen from MLGW's October 2009 bid award, has a maximum

efficiency of 99.09% at a p.u. load of 43% and an efficiency of 99.08% at a 50%

load (DOE). The annual efficiency with a variable load cycle is 98.94%.

Regards,

John Rossetti, P.E.

Systems En gineer

Memphis Light Gas and Water Division

City of Memphis

>>> "Cohen, Daniel" <Daniel.Cohen@hq.doe.gov> 09/23/2011 11:15 AM >>>

Being a simple country lawyer, I’m not sure I quite understand the details of the

analytical suggestions made in the below e

‐ mails, however, I would point out that

DOE’s authority is to estab lish energy conservation standards applicable to

manufacturers of covered products.

I’m not sure how we would set a manufacturer standard based on calculations

performed by purchasers of a product to meet that purchaser’s individual

requirements.

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From: Jerry Hodge [mailto:jhodge@howard

‐ ind.com]

Sent: Thursday, September 22, 2011 5:03 PM

To: Hirsch, Bruce R; Rosenstock, Steven; Richar d Parker; Corkran, Jerry L

Cc: Caitlin Johnson; 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@federalpacific.com; mhyland@appanet.org;

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com;

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@nrdc.org;

robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com;

cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Michael

Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron; Cohen, Daniel;

jmauer@standardsasap.org; greg.coulter405@gmail.com; bsmith@federalpacific.com;pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson;

ahofmann@publicpower.org; BermanEconomics@gmail.com; Paul.Ryan@hitmet.com;

jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com;

chad.kennedy@us.schneider

‐ electric.com;

eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com;

carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider

‐ electric.com;

Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L;

Moore, Jack C; Smith, Jennifer

Subject: RE: Distribution Transformers Committee requested areas for the DOE to

Investigate before final rules are se lected.

To Bruce and All:

I must qualify what I wrote earlier. First of all, I don't want to sound

negative about any of this. Higher efficiencies means energy savings and I'm for

that. TOC is not "dead". We recommend to all of our customers that we should

optimize to meet the DOE th reshold efficiency and at the same time optimize to

get the lowest TOC that still meets the DOE threshold. This may change the ratio

of losses and make the price a little more expensive but it gives the best TOC.

There are a number scenarios with regard to opt imizing:

1. Don't use any TOC formula. You just get the required DOE threshold

efficiency at the lowest price.

2. Customer has a formula but doesn't want to use it, so you get the same result

as no. 1.

3. Customer has a formula but the A and B factors are to o low to be effective,

so you get the same result as no. 1.

4. Customer has a formula and the A and B factors are effective, so

you get the best TOC design that probably changes the ratio of core loss to

conductor loss and it may cost a litt le more, but it still meets the DOE

Efficiency.

5. Customer has a formula that has high A and B factors, so you get a design

that has the best TOC and it has an efficiency greater than the DOE threshold

value and it costs more.

These are the main s cenarios, there may be others. The point I want to make is

that we encourage customers to continue to use TOC and buy based on it. There is

now a tendency to forget about using the TOC approach and just depend on meeting

DOE requirements.

So,TOC is still alive and we e ncourage everyone to use it.

Jerry

Jerry HodgeConsulting 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 conf idential, may be legally

privileged, and is intended only for the use of the intended recipient(s). If

you, the reader of this message, are not an intended recipient hereof, you are

hereby notified that you should not further disseminate, distribute, or forward

this e

‐ mail message. If you have received this e

‐ mail me ssage in error, please

notify the sender as soon as possible by return e

‐ mail message or by telephone at

(601) 425

‐ 3151. In addition, please delete the erroneously received message and

any reply from your system and any device/media where the message is stored.

________________________________

‐‐‐‐‐ Original Message

‐‐‐‐‐

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

Sent: Thursday, September 22, 2011 2:54 PM

To: Jerry Hodge; Rosenstock, Steven; Richard Parker; Corkran, Jerry L

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org;

ScottB@lvmetals.com; john.caskey@nema.org; john.cymbalsky@ee.doe.gov;

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com;

carlos.gaytan@ge.com; rgreeson@federalpacific.com; mhyland@appanet.org;

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com;

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@nrdc.org;

robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com;

cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Mich ael

Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron;

Daniel.Cohen@hq.doe.gov; jmauer@standardsasap.org; greg.coulter405@gmail.com;

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil

Hopkinson; ahofmann@publicpower.org; BermanEconomics@gmail.com;

Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org;

kwinder@mleainc.com; chad.kennedy@us.schneider

‐ electric.com;

eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com;

carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider

‐ electric.com;

Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L;

Moore, Jack C; Smith, Jennifer

Subject: RE: Distribution Transformers Committee requested a reas for the DOE to

Investigate before final rules are selected.

Jerry on other Team Members,

With a one size fits all philosophy, we know that the product is going to be too

large in some cases and too small in others. Unfortunately only a small

percentage will fit correctly.

In a tr ansformer world, those of us using TOC evaluations have been buying the

correct size for 40 years and the Industry is well prepared to handle supplying

the correct size to any and all comers. Seems that we are moving from a veryefficient micro

‐ management of the issue to a macro management that is forcing

inefficiencies upon us and driving up costs for our customers. I might be able to

accept the higher costs if I could see an improved product but in this case our

customers (of the utilities that have been buyi ng via TOC evaluations) are being

forced to pay for inefficiencies.

We need to convince those not in the Utility Industry that the majority of the

Industry have been maximizing transformer efficiency for many years. And I fully

support forcing those who haven’t to adopt procedures to maximize efficiency. The

problem as I see it is that we gone a way from a proven theoretical approach to a

shotgun approach that is missing most of the targets. I don’t understand why

everyone else doesn’t see that. Maybe I am missing something!

Bruce

From: Jerry Hodge [mailto:jhodge@howard

‐ ind.com]

Sent: Thursday, S eptember 22, 2011 3:34 PM

To: Hirsch, Bruce R; Rosenstock, Steven; Richard Parker; Corkran, Jerry L

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org;

ScottB@lvmetals.com; john.caskey@nema.org; john.cymbalsky@ee.doe.gov;

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com;

carlos.gaytan@ge.com; rgreeson@federalpacific.com; mhyland@appanet.org;

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com;

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@nrdc.org;

robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com;

cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Michael

Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron;

Daniel.Cohen@hq.doe.gov; jm auer@standardsasap.org; greg.coulter405@gmail.com;

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil

Hopkinson; ahofmann@publicpower.org; BermanEconomics@gmail.com;

Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org;

kwinder@mleainc.com; chad.kennedy@us.schneider

‐ electric.com;

eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com;

carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider

‐ electric.com;

Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L;

Moore, Jack C; Smith, Jennifer

Subject: RE: Distribution Transformers Committee requested areas for the DOE to

Investigate befor e final rules are selected.

To Bruce and All;

Since 1992, when we first fell under the DOE Appliance efficiency rulemaking, I

have pushed to keep the TOC approach to transformer efficiency. I am speaking

now about only liquid

‐ immersed distribution transformers. The users of these

products are well educated utility pe rsonnel, who are trying to minimize their

owning costs which includes the price of the product plus it's operating cost

over the life of the transformer.In all of my comments to DOE, leading up to the first Final Rule in October,

2007, I continued to recommend keeping the TOC approach that had worked so well

for many years. Unfortunately, DOE didn't agree with

me. They want one size to fit all. Therefore some utilities are

forced to over bu y what is economically best for them. Many of the Co

‐ ops and

some Municipals must buy a transformer that is optimized for a 50% load when they

only need one for a 10% load. The one size fits all ends up being a compromise.

That's difficult to do well in a nati on as big and diversified as the USA.

I don't know how we could change back to a TOC approach at this late date or if

there is even any desire to do so.

Jerry

Jerry Hodge

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

Retired V.P. & G.M. of Pole Ty pe 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 confidential, may be legally

privileged, and is intended only for the use of th e intended recipient(s). If

you, the reader of this message, are not an intended recipient hereof, you are

hereby notified that you should not further disseminate, distribute, or forward

this e

‐ mail message. If you have received this e

‐ mail message in error, please

notify the sender as soon as p ossible by return e

‐ mail message or by telephone at

(601) 425

‐ 3151. In addition, please delete the erroneously received message and

any reply from your system and any device/media where the message is stored.

________________________________

‐‐‐‐‐ Original Message

‐‐‐‐‐

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

Sent: Thursday, September 22, 2011 1: 45 PM

To: 'Rosenstock, Steven'; Richard Parker; Corkran, Jerry L

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org;

ScottB@lvmetals.com; john.caskey@nema.org; john.cymbalsky@ee.doe.gov;

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com;

carlos.gaytan@ge.com; rgreeson@federalpacific.com; mhyland@appanet.org;

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com;

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@nrdc.org;

robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com;

cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Michael

Rivest; Jerry Hodge; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron;

Daniel.Cohen@hq.doe.gov; jmauer@standardsasap.org; greg.coulter405@gmail.com;

bsmith@federalpacific.com; pku mar@publicpower.org; Trujillo, Antonio; Phil

Hopkinson; ahofmann@publicpower.org; BermanEconomics@gmail.com;

Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org;

kwinder@mleainc.com; chad.kennedy@us.schneider

‐ electric.com;eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com;

carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider

‐ electric.com;

Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L;

Moore, Jack C; Smith, Jennifer

Subject: RE: Distribution Transformers Committee requested areas for the DOE to

Investigate before final rules are selected.

Richard,

I concur with Mr. Rosenstock’s concerns and would like to point out an underl ying

issue made in bullet two of his email below. That being the concept that it is

actually “less efficient” to try and force every application of distribution

transformers to fit a specific DOE efficiency level.

Since the 1970’s a majority of utility organizations have purchased distribution

transformers based on Total Ow ning Costs (TOC). An IEEE developed equation

provides the utility the opportunity to customize the transformers they purchase

to achieve the most efficient design for their system and their application. The

TOC evaluation takes into account the up

‐ front costs, transformer loading

practices of the utility, local energy c osts and life expectancy of the

transformers for the application under for which they are being purchased. This

is truly the most efficient and most economical application for the utility’s

customers.

The Southeastern Electric Exchange is a group of electric utility companies that

share information and practices to improve performance.

They re present a microcosm of the Utility Industry nationwide but provide a good

cross section of the Industry. I did a quick pole of the Exchange member

Companies and provide the following statistics.

● With regards to transformer loading, the Companies report

an average loading of 37.7%

‐ well below the 50% d esignated in the DOE proposal.

● 80% of the Companies responding to the survey indicate they

run a TOC calculation and utilize that to assist in their transformer purchases.

(Another 10% utilized the TOC methodology until DOE instituted set efficiency

standards in 2010 at which time they switched to buy tran sformers per the DOE

numbers.)

If we truly want to optimize efficiency we need to find a way to take into

account the different situations that exist from Company to Company, application

to application and geographical region to geographical region. DOE should

consider doing away with set efficiency numbers (which co uld never truly optimize

efficiency in all cases) and require all transformer purchases to be done via a

TOC optimization evaluation. DOE could dictate the equation to be used thus

ensuring the essential variables are included for each purchase. They could also

have the transformer manufacturers continue to police the requirements by

requiri ng them to run a TOC evaluation on every transformer manufactured. This

approach would offer a customized approach that ensures true optimization,

efficiency and affordability of transformers purchased under all applications in

the future. Since the majority of Utilities are familiar with the TOC evaluation,

adoption of the new rule co uld be accelerated yielding immediate benefits.We continue to struggle with setting efficiency levels. In fact we are trying to

force every transformer application to fit a specific model.

This is impractical and impossible to accomplish. Allowing transformers to be

customized for each application via a mathematical design which optimizes cost

versus losses over some lifetime makes a lot mo re sense.

We as a Team need to give this some serious thought.

Bruce Hirsch

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

Sent: Wednesday, September 21, 2011 6:04 PM

To: Richard Parker; Corkran, Jerry L

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org;

ScottB@lvmetals.com; john.caskey@nema.org; john.cymbalsky@ee.doe.gov;

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com;

carlos.gaytan@ge.com; rgreeson@federalpacific.com; Hirsch, Bruce R;

mhyland @appanet.org; dave.millure@metglas.com; snadel@aceee.org;

wes.patterson@us.abb.com; Eric.Petersen@aksteel.com;

Raymond.Polinski@atimetals.com; rroy@nrdc.org; robert.saint@nreca.coop;

chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov;

kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; Jerry

Hodge; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron;

Daniel.Cohen@hq.doe.gov; jmauer@standardsasap.org; greg.coulter405@gmail.com;

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil

Hopkinson; ahofmann@publicpower.org; BermanEconomics@gmail.com;

Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org;

kwinder@mleainc.com; chad.kennedy@us.schneider

‐ electric.com;

eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com;

carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider

‐ electric.com;

Marusinec, Richard M; Schneider, Jeffrey A; Loo mans, Michael T; Poole, Raymond L;

Moore, Jack C; Smith, Jennifer

Subject: RE: Distribution Transformers Committee requested areas for the DOE to

Investigate before final rules are selected.

Mr. Parker and others,

Below are other thoughts for the ground rules / negotiations. I believe that

they are critical for the s uccess.

‐ As part of these negotiations, any or all efficiency levels should be on the

table, not just values chosen by DOE consultants.

‐ As part of these negotiations, parties should be able to look at different

efficiency levels for different applications and/or distinct designs. Such

product groupings within a pro duct class would be consistent with other federal

efficiency standards (e.g., efficiency standards for top freezer type

refrigerator/freezers are different from the standards for bottom freezer types,

which are different from side

‐ by

‐ side refrigerator/freezers).‐ As part of these negotiations, any committee member can suggest sub

‐ groups that

can meet “off line” to provide input to the full committee for its consideration.

Thank you for your consideration.

Steve Rosenstock

Manager, Energy Solutions

Edison Electric Institute

srosenstock@eei.org

202

‐ 508

‐ 5465

[cid:image001.gif@01CC79EA.21F14570]

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

Sent: W ednesday, September 21, 2011 1:39 PM

To: Corkran, Jerry L

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org;

ScottB@lvmetals.com; john.caskey@nema.org; john.cymbalsky@ee.doe.gov;

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com;

carlos.gaytan@ge.com; rgreeson@federalpacific.com; bruce.r.hirsch@bge.com;

mhyland@appanet.org; dave.millure@metglas.com; Nadel, Steve;

wes.patterson@us.abb.com; Eric.Petersen@aksteel.com;

Raymond.Polinski@atimetals.com; Rosenstock, Steven; rroy@nrdc.org;

robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com;

cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Michael

Rivest; Jerry Hodge; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron;

Daniel. Cohen@hq.doe.gov; jmauer@standardsasap.org; greg.coulter405@gmail.com;

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil

Hopkinson; ahofmann@publicpower.org; BermanEconomics@gmail.com;

Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org;

kwinder@mleainc.com; chad.kennedy@us.schneider

‐ electric.com;

eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com;

carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider

‐ electric.com;

Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L;

Moore, Jack C; Smith, Jennifer

Subject: Re: Distribution Transformers Committee requested areas for the DOE to

Investigate befor e final rules are selected.

Jerry (and larger group),

Thanks, Jerry, for your comments, queries and suggestions. My apologies to all

for the late notice on the Ground Rules. The compressed time frame for this

rulemaking has us all scrambling, but we will do our best to get key docs to

group w ell in advance of meetings in the future (to the extent that analytical

requirements and resource limitations allow). Most of the ground rules document

is boilerplate for negotiated rulemakings. We had an extensive discussion about

the parts that are not. But given your concern I will re

‐ open the gro undrules

for online discussion, as needed, and clearance. I will do that in a separate

email thread.Would c.o.b Monday be reasonable deadline for comments on groundrules in your

view, with aim of taking online poll towards middle of next week?

As for the deadlines for talks, the Dec 22 term sheet deadline can be altered by

unanimous consent of the group, but you should know that it is real ly a practical

deadline that results from working backwards from the Jan. 30 court deadline

(assuming court approves revised settlement agreement). So regardless of what is

in our ground rules, that will be the de facto deadline for meeting the court

deadline unless and until the plaintiffs agree to further ex tend that deadline.

Your substantive comments are appreciated. I will consult with DOE/Navigant/LBL

staff and develop a joint preliminary response which we will then post online is

some appropriate format for further review and comment.

All best,

Richard Parker

On Tue, Sep 20, 2011 at 3:57 PM, Corkran, Jerry L

<Jerry. Corkran@cooperindustries.com<mailto:Jerry.Corkran@cooperindustries.com>>

wrote:

I am submitting following items for requests for investigation by the DOE. Some

of the questions listed below were presented before or during the first meeting,

but I have not received sufficient information to answer the questions and

requests listed below:

1. A good portion of the recent meetings wer e concerned with the

review and revisions of the ground rules for the Negotiated Rulemaking Working

Group. A copy of this document was issued dated as “Final

9/15/11” during the second day of the meetings. I was concerned and

puzzled about why a legal document of this type was not i ssued well in advance of

the working group meetings. The document has a legal tone and application that

makes its review beyond my capabilities to determine if it is suitable to govern

the working group and its suitability for me to accept w/o reservations. I have

submitted it to a Cooper Po wer Systems attorney for review to determine if it

requires changes before agreeing to its content. I am objecting to the Sept. 23

deadline for comments and suggestions on this item and request that we be able to

submit input on suggested changes after out attorney has an opportunity to re view

the document. At this time I am objecting to the “4. Agreement” rule with

details of the objection or withdrawal of my objections to be made after our

attorney reviews the document. I also object to the 3 d. Deadline for

Negotiations to terminate at Dec.

22, 2011. I suggest that t his date be determined by the working group during the

third meeting in Nov. after the working group has a knowledge of the time needed

to complete the process.

2. Would the DOE provide the actual design information for the

least

‐ cost transformer designs? Sufficient design information should

be incl uded to allow the transformer manufacturers to compare the same design

created on their programs to the DOE created designs.

3. Would the DOE request transformer design quotations from multiple

manufacturers for the transformer efficiency loss levels that the DOE considers

buildable? This would provide the DOE with actual designswhich the manufacturers are capable of building. These designs could

be compared to the designs which the DOE is currently using to generate the

efficiency data projections.

4. Would the DOE request quotations from multiple manufacturers

optimized for the lowest total owning costs at evaluated loss levels that they

are considering. Th e evaluation A and B factors would vary by a 4:1 ratio to

reflect a maximum efficiency at a 50% load. Suggested A and B factors are 0/0,

$4/$1, $8/$2, $12/$3, and $16/$4.

5. The DOE transformer designs show a large scale movement to

amorphous core steel due to it lower los s characteristics. Review of the DOE

transformer designs indicates that there might be a 700% increase in usage of the

amorphous core steel over present annual production of this material. The DOE is

requested to create projections listing what price increases and material

shortages are to be expected if the us e of this material is forced by transformer

efficiency rules that dictate its use.

6. Because there is only one major supplier of amorphous core steel

in the world that meets the efficiency levels used by the DOE in their

optimizations, which is Hitachi in Japan and Metglas in the US (wh ich is owned

by Hitachi); is it legal for a law to be created at the DOE’s suggestion, forcing

the exclusive use of this material in Distribution Transformers to meet the

efficiency requirements chosen by the DOE?

7. The DOE is requested to show that adequate supplies of the

materials produce d within the United States exist to manufacture the required

transformers that will meet the transformer efficiency requirements chosen for

the proposed changes from the existing transformer efficiency requirements. If

sources of materials are required from outside the United States, the DOE is

requested to estimate what jobs will be lost an d the dollar cost within the

United States over the 30 year average and 60 year maximum life of the

transformers as compared to using materials available within the United States.

8. Regarding the assumptions that the DOE made to use an average

distribution transformer life of 30 years in th eir transformer efficiency payback

calculations; the IEEE Transformer committee in the various technical standards

which apply to Distribution transformers

specifies an average life of 20.5 years. We recommend that the 20.5

year average Distribution Transformer life be used by the DOE in their payback

analysis. How did the DOE arrive at the 30 yea r anticipated life?

9. Regarding the payback times used by the DOE, the document 10 CFR

Part 431 was issued on October 12, 2007 to list the required efficiency levels

for distribution transformers. On page 58220 of this document, various payback

intervals between 5.1 and 21.6 years are listed fo r the efficiencies chosen for

this standard. In the Preliminary Technical Document (TSD):Energy Efficiency

Program for Commercial and Industrial Equiptment :Distribution Transformers dated

March 2011, pay back intervals are listed on page ES

‐ 16 Table ES.2.7 for the

various standard levels. The DOE is requested to explain if these pay back

interva ls are based on a change from the existing efficiency standard? If the

change is from the existing efficiency standard, the DOE is requested to add theyears of payback as listed in 19CFR Part 431 to the years listed on the March

2011 document.

10. The DOE used a 50% anticipated loading factor for the 30 year anticipated

average life calculations used in their transformer efficiency evaluations. What

is the source of the 50% loading factor used ov er a 30 year average and 60 year

maximum expected life for the transformers evaluated? The DOE is requested to

consult the power companies to learn what load factors they expect for

transformers in service for up to 60 years. This item is very important,

because as the loading level increases, the eff iciency of an amorphous core

design will decrease when compared to a silicon core design if they are both

optimized to the same A and B factors. The amorphous core design may have a the

higher efficiency at a 50% average loading but, this efficiency advantage will

disappear as the ave rage load increases and the silicon core steel designs become

more efficient than the amorphous core steel designs when they are both optimized

to the same A and B factors.

11. Regarding the payback intervals to be used by the DOE to select the

efficiency levels to be recommended, the level of loading is based on many

assumpt ions that may change, a payback interval of 5 to 10 years is recommended

to avoid forcing transformer purchases based on changeable assumptions that

likely will result in the longer paybacks never happening.

12. Electric autos are expected to take an increasing percentage of th e auto

market. The July 2011 IEEE Power and Energy magazine estimates that in 5 years,

15% of the global new vehicle market will be electric autos. The DOE is

requested to allow for the increased load factor for charging electric vehicles

over the 60 year span they have chose n to consider for transformer loading.

13. The DOE is requested to get in touch with Marketing and/or Business

Development persons at the major auto manufacturers to learn what their

projections are regarding the projected growth and market share for electric

vehicles. What market share do these companies project for electric a utos and

how will that added load to the electrical systems affect the projected average

loading over the next 60 years?

14. For pole type distribution transformers, the higher efficiency designs used

by the DOE to evaluate the transformer efficiencies have a very significant

increase in weight and also in transf ormer overall height. The DOE is requested

to factor in the increased pole loading and related need to replace existing

poles in some cases to allow the mounting of the heavier pole type transformers.

Some of the higher efficiency transformers will have a total weight of twice that

of the existing t ransformer which is being replaced.

15. The DOE is requested to change percentage efficiency targets to a method of

controlling the transformer efficiency using the lowest total owning cost (TOC)

optimized designs using TOC A and B factors written into law to control

transformer efficiencies. The advantage of using the TOC A and B f actors to

control transformer efficiency is that it allows the transformer quotations to

respond to the available materials.

For example if copper conductors are required to meet a specified efficiency,

transformer manufacturers would not be able to quote if a flood cut off thecopper supply. Using the TOC A and B factors, each manufacturer would be allowed

to quote, if they used the correct A and B factors. Another example is if the

customer prefers to raise the basic insulation level (bil) of the requested

transformer design, the manufacturers will optimize to the specified bil usi ng

the correct A and B factors. The end result is that the higher bil would be just

slightly less efficient than a lower bil because of the added insulation

required to obtain the higher basic insulation level. I raised this

question during the first meeting, but did not receive a res ponse from the DOE

about this subject

, therefore I am requesting that this subject be considered

and responded to by the DOE before they proceed with the final rule making. The

total owning cost approach will handle the variations that occur within the

industry and also result in a similar

improve ment in efficiency as would transformer efficiency targets. It

will allow the transformer efficiencies to be increased as justified, using all

the factors they are currently using to create target transformer efficiencies.

The DOE approach currently uses A and B loss evaluation factors in their

evaluations of what transformer effic iencies

are justified. The A and B loss evaluation factors could be written

into the law rather than specifying the transformer efficiencies. The

law could require that all manufacturers only quote total owning cost optimized

designs using these A and B factors for all quotations, just

as they are now f orced to quote target efficiencies. The transformer

manufacturers would be required to maintain files showing they met the law by

only quoting designs which were optimized using the A and B factors according to

the total owning cost method of reducing transformer losses. Utility companies

have a familiarity with the Total Own ing Cost approach to transformer purchases

because they have routinely used the TOC method of obtaining efficient

transformer designs since about 1980.

Regards,

Jerry Corkran

Staff Engineer

Cooper Power Systems

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