DOE/EA-1565

ENVIRONMENTAL ASSESSMENT

FOR ADOPTED ENERGY CONSERVATION STANDARDS FOR

DISTRIBUTION TRANSFORMERS

July 2007

U.S. Department of Energy

Assistant Secretary

Office of Energy Efficiency & Renewable Energy

Building Technologies Program

Appliances and Commercial Equipment Standards

Washington, DC 20585
EA-i

ENVIRONMENTAL ASSESSMENT FOR ADOPTED ENERGY CONSERVATION

STANDARDS FOR DISTRIBUTION TRANSFORMERS

TABLE OF CONTENTS

1.0 INTRODUCTION ................................................. EA-1

2.0 PURPOSE ....................................................... EA-3

3.0 ALTERNATIVES, INCLUDING THE ACTION ......................... EA-5

3.1 No-Action Alternative ......................................... EA-6

3.2 Adopted Action .............................................. EA-6

3.3 Alternative Standards ......................................... EA-6

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT .................. EA-14

4.1 Geography ................................................. EA-14

4.2 Air Resources .............................................. EA-14

4.2.1 Assumptions ......................................... EA-16

4.2.2 Methods ............................................ EA-16

4.3 Socioeconomics ............................................. EA-18

4.4 Environmental Justice ........................................ EA-18

4.5 Energy Consumption ......................................... EA-20

4.6 Noise and Aesthetics ......................................... EA-20

5.0 ENVIRONMENTAL IMPACTS ..................................... EA-20

5.1 Air Quality/Emissions Impacts .................................. EA-20

5.1.1 Power Sector Emissions ................................ EA-20

5.1.2 Discounted Emissions .................................. EA-25

5.1.3 Fuel-Cycle Emissions .................................. EA-26

5.2 Wetlands / Endangered and Threatened Species / Cultural Resources ..... EA-27

5.3 Socioeconomic Impacts ...................................... EA-27

5.4 Environmental Justice Impacts ................................. EA-27

5.5 Energy Consumption Impacts .................................. EA-28

5.6 Noise and Aesthetics ......................................... EA-29

5.7 Summary of Environmental Impacts ............................. EA-29

LIST OF TABLES

Table EA.1 Adopted Standard Levels for Liquid-Immersed Distribution Transformers . EA-4

Table EA.2 Adopted Standard Levels for Medium-Voltage, Dry-Type Distribution

Transformers ............................................... EA-5

Table EA.3 Trial Standard Levels for PC 1 Liquid-Immersed, Medium-Voltage, Single-Phase 

Distribution Transformers ...................................... EA-7

Table EA.4 Trial Standard Levels for PC 2 Liquid-Immersed, Medium-Voltage, Three-Phase

Distribution Transformers ...................................... EA-8

Table EA.5 Trial Standard Levels for PC 5 Dry-Type, Medium-Voltage, Single-Phase

Distribution Transformers (20-45 kV BIL) ......................... EA-9
EA-ii

Table EA.6 Trial Standard Levels for PC 6 Dry-Type, Medium-Voltage, Three-Phase

Distribution Transformers (20-45 kV BIL) ........................ EA-10

Table EA.7 Trial Standard Levels for PC 7 Dry-Type, Medium-Voltage, Single-Phase

Distribution Transformers (46-95 kV BIL) ........................ EA-11

Table EA.8 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers (46-95 kV

BIL) ..................................................... EA-12

Table EA.9 Dry-Type, Medium-Voltage, Single-Phase Distribution Transformers ($96 kV

BIL) ..................................................... EA-13

Table EA.10 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers ($96 kV

BIL) ..................................................... EA-14

Table EA.11 Liquid Immersed Power Sector Emissions ........................ EA-21

Table EA.12 Dry Type Power Sector Emissions .............................. EA-22

Table EA.13 Liquid Immersed Low Economic Growth Power Sector Emissions ...... EA-22

Table EA.14 Dry Type Low Economic Growth Power Sector Emissions ........... EA-23

Table EA.15 Liquid Immersed High Economic Growth Power Sector Emissions ...... EA-23

Table EA.16 Dry Type High Economic Growth Power Sector Emissions ........... EA-24

Table EA.17 Cumulative Power Sector Emissions Impacts for Liquid-Immersed Transformers

........................................................ EA-24

Table EA.18 Cumulative Power Sector Emissions Impacts for Dry-Type Transformers

........................................................ EA-24

Table EA.19 Discounted CO2 Emissions Reductions of the Trial Standard Levels by Design

Line (in millions of metric tons) ................................ EA-25

Table EA.20 Estimated Upstream Emission Factors and Corresponding Percentages of Direct

Power Plant Combustion Emissions ............................. EA-26

Table EA.21 Summary of the Analysis Results for Liquid-Immersed Transformers .... EA-29

Table EA.22 Summary of the Analysis Results for Dry-Type, Medium-Voltage Transformers 

........................................................ EA-30
EA-1

ENVIRONMENTAL ASSESSMENT FOR DISTRIBUTION TRANSFORMERS

1.0 INTRODUCTION

The U.S. Department of Energy (DOE) prepared this distribution transformers

environmental assessment (EA) pursuant to the National Environmental Policy Act of 1969

(NEPA)(42 U.S.C. 4321 et seq.), the regulations of the Council on Environmental Quality (40

CFR parts 1500–1508), and the DOE’s regulations for compliance with NEPA (10 CFR part

1021). 

Title III of the Energy Policy and Conservation Act (EPCA) (42 U.S.C. 6291 et seq.) sets

forth a variety of provisions designed to improve energy efficiency. Part C of title III (42 U.S.C.

6311–6317) establishes an energy-conservation program for “Certain Industrial Equipment” and

includes distribution transformers, the subject of this EA. EPCA states that the Secretary of

Energy shall prescribe testing requirements for those distribution transformers for which the

Secretary makes a determination that energy conservation standards would be technologically

feasible and economically justified, and would result in significant energy savings. Furthermore,

the Secretary shall prescribe, by rule, energy conservation standards for those distribution

transformers for which the Secretary prescribed testing requirements under the first statement. 

(42 U.S.C. 6317) There are no current mandatory national standards for distribution transformers

in the United States.

On October 22, 1997, the Secretary of Energy issued a determination that “based on its

analysis of the information now available, DOE has determined that energy conservation

standards for transformers appear to be technologically feasible and economically justified, and

are likely to result in significant savings.” 62 FR 54809. The Secretary’s determination was

based, in part, on analyses conducted by the Department of Energy’s Oak Ridge National

Laboratory (ORNL). In July 1996, ORNL published a report entitled Determination Analysis of

Energy Conservation Standards for Distribution Transformers, ORNL-6847,1 which assessed

options for setting energy conservation standards. That report was based on information from

annual sales data, average load data, and surveys of existing and potential transformer efficiencies

obtained from several organizations. 

In September 1997, ORNL published a second report entitled Supplement to the

“Determination Analysis” (ORNL-6847) and Analysis of the NEMA Efficiency Standard for

Distribution Transformers, ORNL-6925.2 This report assessed the suggested efficiency levels

contained in the then-newly published National Electrical Manufacturers Association (NEMA)

Standards Publication No. TP 1-1996, Guide for Determining Energy Efficiency for Distribution

Transformers,

3

 along with the efficiency levels previously considered by DOE in the

determination study. The latest downloadable version of TP 1 is available at the NEMA website: 

http://www.nema.org/stds/tp1.cfm#download. In its supplemental assessment, ORNL used a

more accurate analytical model and better transformer market and loading data developed

following the publication of ORNL-6847. Downloadable versions of both ORNL reports are
EA-2

available on the DOE website at: 

http://www.eere.energy.gov/buildings/appliance_standards/commercial/dist_transformers.html

On July 29, 2004, DOE published the advance notice of proposed rulemaking (ANOPR)

and its associated technical support document (TSD).4 At the ANOPR public meeting on

September 28, 2004, as well as during the formal comment period, DOE invited stakeholders to

comment on the following issues: definition and coverage, product classes (PCs), engineering

analysis inputs, design option combinations, the 0.75 scaling rule, modeling of transformer load

profiles, distribution chain markups, discount rate selection and use, baseline determination

through purchase evaluation formulae, electricity prices, load growth over time, life-cycle cost

(LCC) subgroups, and utility deregulation impacts.

On August 5, 2005, DOE posted its draft NOPR analysis for the liquid-immersed and

medium-voltage, dry-type distribution transformers on its website for early public review, along

with spreadsheets for several of these analyses. This early publication of the draft NOPR analysis

included the draft engineering analysis, LCC analysis, national impact analysis, and manufacturer

impact analysis (MIA), and the draft TSD chapters associated with each of these analyses. The

purpose of publishing these four draft analyses was to give stakeholders an opportunity to review

the analyses and prepare recommendations for DOE as to the appropriate standard levels.

On August 4, 2006, DOE published the distribution transformer energy conservation

standards NOPR. 71 FR 44355. In conjunction with the NOPR, DOE also published on its

website the complete TSD for the proposed rule, which incorporated the final analyses DOE

conducted and technical documentation for each analysis. 

On February 9, 2007, DOE issued a notice of data availability and request for comments

(NODA). 72 FR 6186. DOE published this notice in response to stakeholders who had

commented in the NOPR that DOE's proposed standards might prevent or render impractical the

replacement of distribution transformers in certain space-constrained (e.g., vault) installations. In

the NODA, DOE sought comment on whether it should include in the LCC analysis potential

costs related to size constraints of transformers installed in vaults. DOE also requested comment

on an additional option of selecting final efficiency levels for liquid-immersed distribution

transformers by design line. As discussed in the Engineering Analysis (see TSD Chapter 5), DOE

created separate engineering design lines for small and large kVA liquid-immersed distribution

transformers in both the single-phase and the three-phase product classes. In the NODA, DOE

asked stakeholders whether it should select the final efficiency level for liquid-immersed

distribution transformers by looking at its liquid-immersed analytical results in their most

disaggregated form - by design line. Stakeholder comment from the NODA were considered in

formulating the final rule for the energy conservation standard.
EA-3

2.0 PURPOSE

Energy-efficiency standards for distribution transformers are expected to result in savings

in electrical energy. The metric used to measure the efficiency of distribution transformers is

percent efficiency, which is calculated by taking into account no-load losses (which are constant)

and load losses (which vary by the square of the load) at a specified design load. An increase in

the percent efficiency as measured above indicates that the distribution transformer is more

energy-efficient. Details on the technical analysis of increased efficiency levels are provided in the

TSD that accompanies DOE’s adopted energy conservation standard standard.

To analyze improvements in the efficiency of distribution transformers, DOE created six

trial standard levels (TSLs) during the NOPR using the following criteria for determining the

efficiencies:

TSL 1: The NEMA TP 1 standard level

TSL 2: 1/3 of difference between TP 1 and minimum LCC

TSL 3: 2/3 of difference between TP 1 and minimum LCC

TSL 4: Minimum LCC 

TSL 5: Maximum energy savings with no change in LCC

TSL 6: Maximum energy savings (or maximum technologically feasible level)

In response to comments received in response to the NOPR and the NODA, DOE

formulated four recombined standard levels that it evaluated for the final rule for liquid-immersed

transformers. For liquid-immersed transformers, the efficiencies selected using the minimum LCC

produced inconsistencies in the stringency of the single-phase and three-phase efficiency

requirements. Appendix 8I of the TSD provides a detailed discussion of the three-phase to singephase inconsistencies in the NOPR standard levels and DOE’s response to thies issue. To resolve

the issue of inconsistencies between single-phase and three-phase efficiency levels, DOE

formulated four recombined efficiency levels to evaluate for the final rule. The recombined levels

maintain exact consistency between the single-phase and three-phase efficiency levels for TSL A,

B, and C and approximate single-phase and three-phase consistence for TSL D. 

TSL A: Combination of a DL1 TSL5, and a DL3 TSL4 

TSL B: Combination of a DL4 TSL2, and a DL5 TSL4

TSL C: Combination of a DL4 TSL2, and a DL5 TSL3

TSL D: Combination of a DL1 TSL4, a DL4 TSL2, a DL3 TSL2, and a DL5 TSL3

Tables EA.3 through EA.10 provide the precise definitions of the efficiency levels for each

product class. 

For medium-voltage dry-type transformers, DOE selected TSL 2 while for liquidimmersed transformers DOE selected TSL C. Tables EA.1 and EA.2 summarize the adopted

standard levels for the liquid-immersed and medium-voltage, dry-type transformers.
EA-4

Table EA.1 Adopted Standard Levels for Liquid-Immersed Distribution Transformers

Single-Phase Adopted Efficiency Level

TSLC

Three-Phase Adopted Efficiency Level

TSLC

kVA

PC 1

Efficiency

(%)

kVA

PC 2

Efficiency

(%)

10 98.62 15 98.36

15 98.76 30 98.62

25 98.91 45 98.76

37.5 99.01 75 98.91

50 99.08 112.5 99.01

75 99.17 150 99.08

100 99.23 225 99.17

167 99.23 300 99.23

250 99.31 500 99.27

333 99.36 750 99.31

500 99.42 1000 99.36

667 99.46 1500 99.42

833 99.49 2000 99.46

2500 99.49

Note: All efficiency values are at 50% of nameplate rated load, determined according to the DOE test procedure. 
EA-5

Table EA.2 Adopted Standard Levels for Medium-Voltage, Dry-Type Distribution

Transformers

Single-Phase Adopted Efficiency Level

TSL2

Three-Phase Adopted Efficiency Level

TSL2

kVA

PC5

20-45kV

BIL

(%)

PC7

46-95kV

BIL

(%)

PC9

$96kV

BIL

(%)

kVA

PC6

20-45kV

BIL 

(%)

PC8

46-95kV

BIL 

(%)

PC10

$96kV

BIL 

(%)

15 98.10 97.86 - 15 97.50 97.19 -

25 98.33 98.12 - 30 97.90 97.63 -

37.5 98.49 98.30 - 45 98.10 97.86 -

50 98.60 98.42 - 75 98.33 98.12 -

75 98.73 98.57 98.53 112.5 98.49 98.30 -

100 98.82 98.67 98.63 150 98.60 98.42 -

167 98.96 98.83 98.80 225 98.73 98.57 98.53

250 99.07 98.95 98.91 300 98.82 98.67 98.63

333 99.14 99.03 98.99 500 98.96 98.83 98.80

500 99.22 99.12 99.09 750 99.07 98.95 98.91

667 99.27 99.18 99.15 1000 99.14 99.03 98.99

833 99.31 99.23 99.20 1500 99.22 99.12 99.09

2000 99.27 99.18 99.15

2500 99.31 99.23 99.20

Note: All efficiency values are at 50% of nameplate rated load, determined according to the DOE test procedure. 

3.0 ALTERNATIVES, INCLUDING THE ACTION

DOE analyzed 11 alternative standards levels for liquid-immersed transformers and seven

for medium-voltage, dry-type transformers. For the liquid-immersed transformers the alternatives

consisted of the six TSLs identified in the NOPR, four recombinations and a no-action alternative. 

As discussed above, DOE’s adopted action is to propose TSL 2 for medium-voltage, dry-type

transformers and TSL C for liquid-immersed transformers. The following sections discuss the 11

liquid-immersed alternatives and the seven medium-voltage dry-type transformers alternatives.

3.1 No-Action Alternative

Under a no-action alternative, DOE would not publish new minimum energy-efficiency

standards for distribution transformers. DOE addresses the no-action alternative in the TSD,

including the regulatory impact analysis (RIA), along with other non-regulatory policy cases and
EA-6

voluntary incentive programs. The RIA found that the no-action alternative would result in

insufficient reductions in energy consumption as compared to other alternatives, including DOE’s

adopted action.

3.2 Adopted Action

DOE’s action is to adopt TSL C for liquid-immersed transformers and TSL 2 for mediumvoltage, dry-type transformers (as identified in Tables EA.1 and EA.2), which would result in

national energy savings, reduced average LCC for consumers, a net national benefit (i.e.,

monetary savings to the Nation exceed increased equipment costs to the Nation), and air-borne

emissions reductions. The adopted action would also result in a reduction in industry net present

value, but DOE believes the amount is not significant. In this final rule, DOE determined that the

benefits of the adopted action outweighed its burdens and that the action is economically justified. 

DOE concluded that the adopted action would save a significant amount of energy and is

technologically feasible. The adopted action goes into effect in the year 2010. Additional details

on estimated impacts resulting from the adopted action and other TSLs are provided in the TSD.

3.3 Alternative Standards

This EA also presents the results of the environmental impacts from five other distribution

transformer TSLs for medium-voltage, dry-type transformers and nine other TSLs for liquidimmersed transformers—besides those from DOE’s adopted action (TSL 2 and TSL C

respectively). Each TSL is an alternative action, which DOE compared with the no-action

alternative. (In the no-action alternative, also referred to as the base case, no new amended

standards are adopted.) Each TSL has a unique combination of efficiency levels associated with

it. Tables EA.3 through EA.10 show each TSL, including DOE’s adopted action, by product

class. Each of the tables also indicate the specific engineering design lines (DL) associated with

that particular product class at the transformer capacity associated with the particular design lines. 

DOE performed a detailed engineering and economic analysis for each design line and then

extrapolated the results to the product class to estimate the economic and engineering impacts of

alternative standards for the entire population of transformers. Chapter 5 of the TSD presents the

engineering analysis for each of the transformers design lines, while Chapter 8 of the TSD

presents the consumer economic impacts for each engineering design line. 
EA-7

Table EA.3 Trial Standard Levels for PC 1 Liquid-Immersed, Medium-Voltage,

Single-Phase Distribution Transformers

Product

Class 1

Trial Standard Level

0 1 2 3 4 5 6 A B C D

Desig

n

Line

kVA Ave.

Base

Case Eff.

Min.

Base

Case

Eff.

TP 1 Max

Tech.

10 98.42 97.77 98.4 98.40 98.44 98.48 98.69 99.32 98.79 98.62 98.62 98.48

15 98.57 97.99 98.6 98.56 98.59 98.63 98.82 99.39 98.91 98.76 98.76 98.63

DL2 25 98.74 98.23 98.7 98.73 98.76 98.79 98.96 99.46 99.04 98.91 98.91 98.79

37.5 98.86 98.40 98.8 98.85 98.88 98.91 99.06 99.51 99.13 99.01 99.01 98.91

DL1 50 98.97 98.56 98.9 98.90 98.90 99.04 99.19 99.59 99.19 99.08 99.08 99.04

75 99.04 98.66 99.0 99.04 99.06 99.08 99.21 99.59 99.27 99.17 99.17 99.08

100 99.11 98.75 99.0 99.10 99.12 99.14 99.26 99.62 99.32 99.23 99.23 99.14

167 99.22 98.90 99.1 99.21 99.23 99.25 99.35 99.66 99.40 99.32 99.32 99.25

250 99.24 98.89 99.2 99.26 99.36 99.45 99.69 99.70 99.45 99.37 99.31 99.26

333 99.29 98.97 99.2 99.31 99.40 99.49 99.71 99.72 99.49 99.41 99.36 99.31

DL3 500 99.36 99.07 99.3 99.38 99.46 99.54 99.74 99.75 99.54 99.47 99.42 99.38

667 99.40 99.13 99.4 99.42 99.50 99.57 99.76 99.77 99.57 99.51 99.46 99.42

833 99.44 99.18 99.4 99.45 99.52 99.60 99.77 99.78 99.60 99.53 99.49 99.45
EA-8

Table EA.4 Trial Standard Levels for PC 2 Liquid-Immersed, Medium-Voltage,

Three-Phase Distribution Transformers

Product 

Class 2

Trial Standard Level

0 1 2 3 4 5 6 A B C D

Design

Line

kVA Ave.

Base

Case

Eff.

Min.

Base

Case

Eff,

TP 1 Max

Tech.

15 98.06 97.19 98.1 98.36 98.68 98.68 99.25 99.31 98.56 98.36 98.36 98.36

30 98.37 97.64 98.4 98.62 98.89 98.89 99.37 99.42 98.79 98.62 98.62 98.62

45 98.53 97.87 98.6 98.76 99.00 99.00 99.43 99.47 98.91 98.76 98.76 98.76

75 98.70 98.12 98.7 98.91 99.12 99.12 99.50 99.54 99.04 98.91 98.91 98.91

112.5 98.83 98.30 98.8 99.01 99.20 99.20 99.55 99.58 99.13 99.01 99.01 99.01

DL4 150 98.91 98.42 98.9 99.08 99.26 99.26 99.58 99.61 99.19 99.08 99.08 99.08

225 99.02 98.57 99.0 99.17 99.33 99.33 99.62 99.65 99.27 99.17 99.17 99.17

300 99.08 98.67 99.0 99.23 99.38 99.38 99.65 99.67 99.32 99.23 99.23 99.23

500 99.19 98.83 99.1 99.32 99.45 99.45 99.69 99.71 99.40 99.32 99.32 99.32

750 99.24 98.97 99.2 99.24 99.31 99.37 99.66 99.66 99.45 99.37 99.31 99.31

1000 99.29 99.04 99.2 99.29 99.36 99.41 99.68 99.68 99.49 99.41 99.36 99.36

DL5 1500 99.36 99.13 99.3 99.36 99.42 99.47 99.71 99.71 99.54 99.47 99.42 99.42

2000 99.40 99.19 99.4 99.40 99.46 99.51 99.73 99.73 99.57 99.51 99.46 99.46

2500 99.44 99.23 99.4 99.44 99.49 99.53 99.74 99.74 99.60 99.53 99.49 99.49
EA-9

Table EA.5 Trial Standard Levels for PC 5 Dry-Type, Medium-Voltage, Single-Phase

Distribution Transformers (20-45 kV BIL)

Product 

Class 5

Trial Standard Level

0 1 2 3 4 5 6

Design

Line

kVA Ave. Base

Case Eff.

Min. Base

Case Eff.

TP 1 Max

Tech.

15 98.02 97.45 97.6 98.10 98.46 98.81 99.05 99.05

25 98.26 97.75 97.9 98.33 98.64 98.95 99.17 99.17

37.5 98.43 97.97 98.1 98.49 98.77 99.05 99.25 99.25

50 98.54 98.11 98.2 98.60 98.86 99.12 99.30 99.30

75 98.68 98.29 98.4 98.73 98.97 99.20 99.37 99.37

DL9 100 98.77 98.41 98.5 98.82 99.04 99.26 99.41 99.41

167 98.92 98.60 98.8 98.96 99.16 99.35 99.48 99.48

250 99.01 98.56 98.9 99.05 99.17 99.27 99.42 99.42

333 99.08 98.66 99.0 99.11 99.23 99.32 99.46 99.46

DL10 500 99.17 98.79 99.1 99.20 99.30 99.39 99.51 99.51

667 99.23 98.87 99.2 99.26 99.35 99.43 99.54 99.54

833 99.27 98.93 99.2 99.30 99.38 99.46 99.57 99.57
EA-10

Table EA.6 Trial Standard Levels for PC 6 Dry-Type, Medium-Voltage, Three-Phase

Distribution Transformers (20-45 kV BIL)

Product 

Class 6

Trial Standard Level

0 1 2 3 4 5 6

Design

Line

kVA Ave. Base

Case Eff.

Min. Base

Case Eff.

TP 1 Max Tech.

15 97.40 96.64 96.8 97.50 97.97 98.44 98.75 98.75

30 97.81 97.17 97.3 97.90 98.29 98.68 98.95 98.95

45 98.02 97.45 97.6 98.10 98.46 98.81 99.05 99.05

75 98.26 97.75 97.9 98.33 98.64 98.95 99.17 99.17

112.5 98.43 97.97 98.1 98.49 98.77 99.05 99.25 99.25

150 98.54 98.11 98.2 98.60 98.86 99.12 99.30 99.30

225 98.68 98.29 98.4 98.73 98.97 99.20 99.37 99.37

DL9 300 98.77 98.41 98.6 98.82 99.04 99.26 99.41 99.41

500 98.92 98.60 98.8 98.96 99.16 99.35 99.48 99.48

750 99.01 98.56 98.9 99.05 99.17 99.27 99.42 99.42

1000 99.08 98.66 99.0 99.11 99.23 99.32 99.46 99.46

DL10 1500 99.17 98.79 99.1 99.20 99.30 99.39 99.51 99.51

2000 99.23 98.87 99.2 99.26 99.35 99.43 99.54 99.54

2500 99.27 98.94 99.2 99.30 99.38 99.46 99.57 99.57
EA-11

Table EA.7 Trial Standard Levels for PC 7 Dry-Type, Medium-Voltage, Single-Phase

Distribution Transformers (46-95 kV BIL)

Product 

Class 7

Trial Standard Level

0 1 2 3 4 5 6

Design

Line

kVA Ave. Base

Case Eff.

Min. Base

Case Eff.

TP 1 Max Tech.

15 97.46 96.87 97.6 97.86 98.14 98.41 98.54 98.54

25 97.77 97.24 97.9 98.12 98.36 98.60 98.71 98.71

37.5 97.98 97.51 98.1 98.30 98.52 98.73 98.84 98.84

50 98.12 97.68 98.2 98.42 98.62 98.82 98.92 98.92

75 98.30 97.90 98.4 98.57 98.75 98.94 99.02 99.02

DL11 100 98.42 98.05 98.5 98.67 98.84 99.01 99.09 99.09

167 98.61 98.28 98.8 98.83 98.98 99.13 99.20 99.20

250 99.02 98.58 98.9 98.95 99.08 99.23 99.42 99.42

333 99.09 98.68 99.0 99.03 99.15 99.28 99.46 99.46

DL12 500 99.18 98.81 99.1 99.12 99.23 99.35 99.51 99.51

667 99.24 98.89 99.2 99.18 99.28 99.40 99.54 99.54

833 99.28 98.95 99.2 99.23 99.32 99.43 99.57 99.57

Note: Because the representative units for both of the underlying DLs for PC 7 (DL 11 and DL 12) were 95 kV

BIL, for kVA ratings from 167 through 833, the value in the “TP 1” column is the NEMA TP 1 value for >60 kV

BIL.
EA-12

Table EA.8 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers (46-95

kV BIL)

Product 

Class 8

Trial Standard Level

0 1 2 3 4 5 6

Design

Line

kVA Ave.

Base

Case Eff.

Min.

Base

Case Eff.

TP 1 Max

Tech.

15 96.66 95.88 96.8 97.19 97.55 97.91 98.08 98.08

30 97.19 96.53 97.3 97.63 97.94 98.24 98.38 98.38

45 97.46 96.87 97.6 97.86 98.14 98.41 98.54 98.54

75 97.77 97.24 97.9 98.12 98.36 98.60 98.71 98.71

112.5 97.98 97.51 98.1 98.30 98.52 98.73 98.84 98.84

150 98.12 97.68 98.2 98.42 98.62 98.82 98.92 98.92

225 98.30 97.90 98.4 98.57 98.75 98.94 99.02 99.02

DL11 300 98.42 98.05 98.5 98.67 98.84 99.01 99.09 99.09

500 98.61 98.28 98.8 98.83 98.98 99.13 99.20 99.20

750 99.02 98.58 98.9 98.95 99.08 99.23 99.42 99.42

1000 99.09 98.68 99.0 99.03 99.15 99.28 99.46 99.46

DL12 1500 99.18 98.81 99.0 99.12 99.23 99.35 99.51 99.51

2000 99.24 98.89 99.2 99.18 99.28 99.40 99.54 99.54

2500 99.28 98.95 99.2 99.23 99.32 99.43 99.57 99.57

Note: Because the representative units for both of the underlying DLs for PC 8 (DL 11 and DL 12) were 95 kV

BIL, for kVA ratings from 300 through 2500, the value in the “TP 1”column is the NEMA TP 1 value for >60 kV

BIL.
EA-13

Table EA.9 Dry-Type, Medium-Voltage, Single-Phase Distribution Transformers ($96

kV BIL)

Product 

Class 9

Trial Standard Level

0 1 2 3 4 5 6

Design

Line

kVA Ave. Base

Case Eff.

Min. Base

Case Eff.

TP 1 Max Tech.

75 98.72 98.22 98.4 98.53 98.79 99.05 99.22 99.22

100 98.81 98.34 98.5 98.63 98.88 99.12 99.28 99.28

167 98.95 98.54 98.7 98.80 99.01 99.22 99.36 99.36

250 99.05 98.68 98.8 98.91 99.11 99.30 99.42 99.42

333 99.12 98.77 98.9 98.99 99.17 99.35 99.46 99.46

500 99.20 98.89 99.0 99.09 99.25 99.41 99.52 99.52

DL13 667 99.26 98.97 99.0 99.15 99.30 99.45 99.55 99.55

833 99.30 99.03 99.1 99.20 99.34 99.48 99.57 99.57
a

 The EIA approves use of the name NEMS to describe only an official version of the model without any

modification to code or data. Because this analysis entails some minor code modifications and the model is run

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it as NEMS-BT. 

NEMS-BT was previously called NEMS-BRS.

EA-14

Table EA.10 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers ($96

kV BIL)

Product 

Class 10

Trial Standard Level

0 1 2 3 4 5 6

Design

Line

kVA Ave. Base

Case Eff.

Min. Base

Case Eff.

TP 1 Max Tech.

225 98.72 98.22 98.4 98.53 98.79 99.05 99.22 99.22

300 98.81 98.34 98.5 98.63 98.88 99.12 99.28 99.28

500 98.95 98.54 98.7 98.80 99.01 99.22 99.36 99.36

750 99.05 98.68 98.8 98.91 99.11 99.30 99.42 99.42

1000 99.12 98.78 98.9 98.99 99.17 99.35 99.46 99.46

1500 99.20 98.89 99.0 99.09 99.25 99.41 99.52 99.52

DL13 2000 99.26 98.97 99.0 99.15 99.30 99.45 99.55 99.55

2500 99.30 99.03 99.1 99.20 99.34 99.48 99.57 99.57

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT

4.1 Geography

The distribution transformer standard that DOE has adopted–TSL 2 for medium-voltage,

dry-type and TSL C for liquid-immersed–would apply to all 50 States and United States

territories. 

4.2 Air Resources

The primary focus of the EA is the effect of adopted efficiency standards on air resources. 

For this analysis, the EA used a variant of the DOE Energy Information Administration (EIA)’s

National Energy Modeling System (NEMS), called NEMS-BT (BT is DOE’s Building

Technologies Program).a As described in section 4.2.1 below, the environmental analysis is

similar to the utility impact analysis described in Chapter 13 of the TSD.5 Outputs of the

environmental analysis are in a format similar to the results of the EIA’s Annual Energy Outlook

2006 (AEO2006).

6
EA-15

For each of the energy-efficiency standard levels, DOE calculated total power-sector

emissions based on output from NEMS-BT. The EA considers one emission, carbon dioxide

(CO2). An air pollutant is any substance in the air that can cause harm to humans or the

environment. Pollutants may be natural or man-made and may take the form of solid particles,

liquid droplets, or gases. The Clean Air Act Amendments of 1990 list 188 toxic air pollutants that

the U.S. Environmental Protection Agency (EPA) is required to control. The EPA has set

national air-quality standards for six common pollutants (also referred to as “criteria” pollutants),

two of which are SO2 and NOx. Also, the Clean Air Act Amendments of 1990 gave authority to

EPA to control acidification and to require operators of electric power plants to reduce emissions

of SO2 and NOx. In addressing SO2 emissions, the Clean Air Act Amendments of 1990 set an SO2

emissions cap on all power generation, but permitted flexibility among generators through the use

of emissions allowances and tradable permits. This SO2 trading implies that physical emissions

effects of a standard is likely to be zero because emissions will always be at, or near, the allowed

ceiling. Consequently, there is no direct SO2 environmental benefit from electricity conservation,

as long as there is enforcement of the emissions ceiling. But to the extent reduced power

generation demand decreases the demand for and price of emissions allowance permits, there is

potentially an environmentally related economic benefit from standards reducing SO2 emissions

allowance demand. 

In March 2005, EPA legislated the Clean Air Interstate Rule (CAIR). This rule was

designed to further reduce atmospheric releases of ozone and particulate matter and therefore

targets NOx and SO2 emissions. Applicable to 28 States and the District of Columbia, all fossilfueled boilers and turbines greater than 25 MW including CHP units greater than 25 MW are

required to reduce their NOx and SO2 emissions in a two-phase program. Under CAIR, States are

responsible for allocating emissions allowances, giving emitters the choice of participating in capand-trade programs or adopting control technologies to meet their requirements.

Carbon dioxide is of interest because of its classification as a greenhouse gas and its

impact on global climate change. Greenhouse gases — which trap the sun’s radiation inside the

Earth’s atmosphere — either occur naturally in the atmosphere or result from human activities. 

Naturally occuring greenhouse gases include water vapor, CO2, methane (CH4), nitrous oxide,

and ozone. Human activities, however, add to the levels of most of these naturally occurring

gases. For example, CO2 is emitted to the atmosphere when solid waste, fossil fuels (oil, natural

gas, and coal), wood, and wood products are burned. During the past 20 years, about

three-quarters of anthropogenic (i.e., human-made) CO2 emissions resulted from burning fossil

fuels. Concentrations of CO2 in the atmosphere are naturally regulated by numerous processes,

collectively known as the “carbon cycle.” The movement of carbon between the atmosphere and

the land and oceans is dominated by natural processes, such as plant photosynthesis. While these

natural processes can absorb some of the anthropogenic CO2 emissions produced each year,

billions of metric tons are added to the atmosphere annually. The Earth’s positive imbalance

between emissions and absorption results in the continuing growth in greenhouse gases in the

atmosphere, thereby causing surface air temperatures and sub-surface ocean temperatures to rise. 

The U.S. CO2 emissions from both energy consumption and industrial processes account for 84.6

percent of total U.S. greenhouse gas emissions.7
b

 While the AEO2007 electricity price forecast data was available in time for preparation of this final rule, the full

AEO2007 forecast was not available at the time DOE performed the utility and environmental impact analysis. 

DOE therefore used AEO2006 for the utility and environmental analysis. Following completion of the utility and

environmental analysis and after the full AEO 2007 became available, DOE compared the AEO2006 and AEO2007

and found the forecasts of electricity prices, the marginal generation mix and emissions factors in the AEO2007

and AEO2006 forecasts were very similar. The two forecasts provide the same marginal fractions of coal and

natural gas generation (within 3.5%), and have marginal CO2 emission factors that differ by less than 2%. DOE

provides details of the AEO2006 and AEO2007 comparison in Chapter 13 of the TSD

EA-16

4.2.1 Assumptions

In its forecasts of air resources impacts using NEMS-BT, DOE conducted the EA as a

policy deviation from the typical meteorological year (TMY) System Load Reference Case, a

modified AEO2006 Reference Case, using the same basic set of assumptions. The emissions

characteristics of all electricity-generating plants are exactly as those used in AEO2006.

b

 The

TMY System Load Reference Case and alternative growth scenarios are as described in the utility

impact analysis of the TSD (Chapter 13). DOE derived the environmental impacts of the adopted

standard using the same higher decrement, double-decrement approach described in the utility

impact analysis.

As in the utility impact analysis, DOE substituted the default NEMS system load with a

system load that represents weather conditions for a TMY—here referred to as the TMY system

load. As a result, the reference case used to judge the impacts from a adopted distribution

transformer standard is no longer an exact replication of the AEO2006 Reference Case and is

therefore referred to as the TMY System Load Reference Case.

The EA also includes a sensitivity analysis for the adopted standard level, using the High

and Low Economic Growth scenarios of NEMS-BT. As described in Chapter 13 of the TSD,

these scenarios cover a range of macro-economic growth assumptions. 

4.2.2 Methods

CO2. The NEMS-BT tracks CO2 emissions using a detailed CO2 module that features

broad coverage of all sectors and includes interactive effects. Past experience with NEMSgenerated CO2

 emissions suggests estimates are somewhat lower than estimates based on simple

average factors. One of the reasons for this divergence is that NEMS tends to predict that

conservation displaces more-efficient generating capacity in the later years of its forecast.

Power Sector NOx and Hg. The NEMS-BT reports the two airborne pollutant emissions

that DOE has considered in past analyses, SO2 and NOx and now also reports Hg emissions. The

NEMS-BT estimates NOx and Hg emissions from power generation by assuming that the power

sector conforms to all pre-2005 legislation and regulations with respect to monitoring power

facility development, retrofitting, and dispatch, including potential installations of emissions-
EA-17

reducing equipment (i.e., scrubbers). Three recent regulatory actions adopted by the

EPA—regarding (1) regulations and guidelines for best-available retrofit technology

determinations, (2) the reduction of interstate transport of fine particulate matter and ozone—are

tending toward further NOx reductions and has lead to an emissions cap on NOx for the Eastern

United States. 69 FR 25184 (May 5, 2004), 69 FR 32684 (June 10, 2004), and 70 FR 25162

(May 12, 2005), and (3) the recent promulgation of the mercury emissions rule has resulted in a

cap on Hg emissions 70 FR 28606 (May 18, 2005). As with SO2 emissions, a cap on NOx and Hg

emissions will likely result in no physical emissions effects from equipment efficiency standards.

Because NOx and Hg have been regulated with emissions caps, and no emissions reductions are

reported from the NEMS-BT forecast model, DOE does not report NOx and Hg results here. 

Power Sector SO2. As explained above, accurate simulation of SO2 trading tends to imply

that physical emissions effects will be zero, as long as emissions are at the allowed ceiling. 

Because SO2 has been regulated with emissions caps for more than a decade, and no emissions

reductions are reported from the NEMS-BT forecast model, DOE does not report SO2 results

here. 

Fuel-Cycle Emissions. Fuel-cycle emissions refer to the emissions associated with the

amount of energy used in the upstream production and downstream consumption of electricity,

including energy used at the power plant. Upstream processes include the mining of coal or

extraction of natural gas, physical preparatory and cleaning processes, and transportation to the

power plant. he NEMS-BT does a thorough accounting of emissions at the power plant due to

downstream energy consumption, but does not account for upstream emissions (i.e., emissions

from energy losses during coal and natural gas production). Thus, this EA reports only power

plant emissions.

Interpolation. Because the energy savings from distribution transformer standards are too

small to produce stable power sector results in NEMS-BT, DOE estimated results for the TSLs

using interpolation. To run a simulation in NEMS-BT, the system electricity load and commercial

demand use are reduced annually according to the energy savings estimated by the national energy

savings (NES) Spreadsheet Model (see Chapter 10 of the TSD) for each TSL. These energy

savings increase over time. The magnitude of the energy decrement that would be required for

NEMS-BT to produce stable results out of the range of numerical noise is greater than the highest

standard level under consideration. Therefore, to estimate results for the TSLs considered here,

DOE carried out a series of NEMS-BT runs using higher values for the input energy savings. 

These runs established the relationship between the NEMS-BT outputs (e.g., installed capacity

reductions, emissions reductions) and the energy savings inputs. DOE then obtained results for

energy savings corresponding to the TSLs using linear interpolation. 

DOE then used the estimated reduction in total fuel generation at each TSL, as determined

by interpolation, to determine emissions savings. First, it calculated annual marginal emissions

rates for each of the simulations in each standard level, based on the actual output from NEMSBT. Marginal emissions rates incorporate both effects of the standards—the emissions saved by

the reduction in total generation, and the slight change in the emissions characteristics of the
EA-18

whole power sector that result from the slight change in dispatch and capacity expansion plan.

The net effect on the entire system is very small and, typically, the overall effect on emissions can

be fully attributed to the reduced generation capacity. DOE could then determine annual marginal

emissions rates at the trial standard level from these rates (at multipliers of the TSL savings), by

taking a simple average. 

Extrapolation. The current time horizon of NEMS-BT is 2030 (modeling a 20-year

period, 2010–2030); however, other parts of the distribution transformer rulemaking analysis

extend to 2038. It is not feasible to extend the forecast period of NEMS-BT for the purposes of

this analysis nor does DOE/EIA have an approved method for extrapolation of many outputs

beyond 2030. While it might seem reasonable in general to make simple linear extrapolations of

results, in practice this is not advisable because outputs could be contradictory. For example,

changes in the fuel mix implied by extrapolations of those outputs could be inconsistent with the

extrapolation of marginal emissions factors. An analysis of various trends sufficiently detailed to

guarantee consistency is beyond the scope of this work, and, in any case, would involve a great

deal of uncertainty. Therefore, all extrapolations beyond 2030 are simple replications of year

2030 results. While these may seem unreasonable in some instances, in this way results are

guaranteed to be consistent. As with the AEO Reference Case in general, the implicit assumption

is that the regulatory environment does not deviate from the current known situation during the

extrapolation period. Only changes that have been announced with date-certain introduction are

included in NEMS-BT. To emphasize the extrapolated results wherever they appear, they are

shaded in grey to distinguish them from actual NEMS-BT results.

4.3 Socioeconomics

As part of the rulemaking process, DOE evaluated the socioeconomic effect on small

businesses, especially small manufacturers, a subgroup that DOE identified as possibly being

disproportionately affected by a national standard level. Converting from a company’s current

basic product line involves designing, prototyping, testing, and manufacturing a new product. 

These tasks have associated capital investments and product conversion expenses. Small

businesses, because of their limited access to capital and their need to spread product conversion

expenses over smaller production volumes, may be affected more negatively than major

manufacturers by an energy-conservation standard. For these reasons, DOE specifically evaluated

the impacts on small businesses from an energy-conservation standard. Chapter 12 of the TSD

provides more details on the manufacturer subgroup analysis. 

4.4 Environmental Justice

According to Executive Order 12898 of February 11, 1994, "Federal Actions to Address

Environmental Justice in Minority Populations and Low-Income Populations," 59 FR 7629

(February 16, 1994), DOE is required to examine the effect of more stringent energy efficiency

standards on (1) small businesses that either manufacture or use distribution transformers, (2)
EA-19

manufacturers of niche products related to distribution transformers, and (3) small businesses

operated by disadvantaged or minority populations.

Regarding users of distribution transformers, small businesses are included as part of the

overall population examined by DOE in the LCC analysis. The results of that analysis estimated

that between 26 and 61 percent of distribution transformer customers would experience positive

economic impacts from the proposed standard. 

Small distribution transformer manufacturing enterprises, as defined by the Small Business

Administration, are those with no more than 750 employees. DOE identified and interviewed six

small manufacturers of distribution transformers, five of which produce medium-voltage, dry-type

transformers and one of which produces liquid-immersed transformers. Because the

liquid-immersed distribution transformer industry largely produces customized transformers, small

businesses can compete because each unique design is produced in relatively small volumes for a

given customer's order. Implementation of an energy conservation standard would have a

relatively minor differential impact on small manufacturers of liquid-immersed distribution

transformers. 

Because of the potential impacts of a standard on manufacturers of the medium-voltage,

dry-type transformers, DOE determined that it cannot certify that the proposed rule (TSL2), if

promulgated, would have no significant economic impact on a substantial number of small

entities. Because DOE cannot certify this, due to the potential impacts on medium-voltage,

dry-type manufacturers, it prepared an initial regulatory flexibility analysis (IRFA) for this

rulemaking, which can be found in section VI.B of the NOPR. For additional information on this

subject, see also section V.B.2.b of the NOPR and the manufacturer impact analysis (MIA) in

Chapter 12 of the TSD.

DOE did not conduct a separate analysis to assess the impacts of a new standard on niche

product manufacturers because it found no niche products for which the adoption of a new

standard would raise special considerations.

DOE's LCC subgroup analysis (TSD Chapter 11) did not include small or disadvantaged

businesses or populations as a subgroup. However, DOE believes that there are no

disproportionately high and adverse human health or environmental effects on minority

populations, and low-income populations resulting from more stringent energy efficiency

standards. Positive impacts, such as decreased air emissions, would be equally shared among all

populations.

The MIA (TSD Chapter 12), and the regulatory impact analysis (published with the TSD)

examined impacts on various business populations. However, DOE received no data concerning

differential impacts on businesses owned by minority or disadvantaged populations.
EA-20

4.5 Energy Consumption

DOE used a detailed shipments and NES Spreadsheet Model to determine national energy

savings as a result of increases in the minimum efficiency standard. This spreadsheet model

forecasts the national shipments and energy use of distribution transformers with and without new

standards. The shipments and NES analyses are described in detail in TSD Chapters 9 and 10,

respectively.

4.6 Noise and Aesthetics

DOE considered how new energy conservation standards for distribution transformers

may affect the noise and aesthetics of the equipment. To improve the efficiency of distribution

transformers, increased amounts of heavier materials (e.g., steel) may be used that can enlarge the

size of the equipment. DOE reviewed these components to determined if noise and aesthetics

were impacted. DOE determined that the adopted standard would result in less than 10% increase

in the volume distribution transformers and that the higher efficiency transformers are likely to

have the same noise characteristics as existing transformers. Therefore, DOE estimates that there

will be no significant impact on noise and aesthetics from the adopted standard. 

5.0 ENVIRONMENTAL IMPACTS

5.1 Air Quality/Emissions Impacts

5.1.1 Power Sector Emissions

The results for the environmental analysis are similar to a complete NEMS run as

published in the AEO2006, and include power sector emissions for CO2 in five-year forecast

increments, extrapolated to the year 2038. DOE reports the outcome of the analysis for each

TSL as a deviation from the TMY System Load Reference Case. This is also referred to as the

base case. 

As discussed in section 4.2, the Clean Air Act Amendments of 1990 set an SO2 emissions

cap on all power generation, but permitted flexibility among generators through the use of

emissions allowances and tradable permits. Similar rules provide power sector emissions caps on

NOX and Hg. Moreover, emissions trading implies that physical emissions effects of a standard

will be zero because emissions will always be at, or near, the ceiling. Consequently, there is

virtually no physical emissions reduction benefit for these pollutants from electricity conservation

as long as there is enforcement of the emissions ceiling. Even though there is no physical

environmental benefit from adopted standards, there are potential environmental economic

benefits. Given reduced demand for coal generation, there is reduced demand for emission

allowances and this may lower the allowance price and traded allowance volume. For these

reasons, DOE’s emissions reduction forecast from NEMS-BT indicated no significant emissions

reductions from the adopted standard for SO2, NOX and Hg. Thus, DOE did not report these

quantities. 
EA-21

Tables EA.11 through EA.15 show annual total power sector CO2 emissions for the

various distribution transformer TSLs for each superclass. The liquid-immersed class considers

10 TSLs while the medium-volgate, dry-type class considers six TSLs. Annual CO2 emissions

reductions are the highest for liquid-immersed TSL 6 and are the lowest for medium-voltage, drytype TSL 1. Tables EA.16 through EA.18 show the results for the cumulative emissions

reductions through 2030 and 2038 for CO2.

The results for the Low and High Economic Growth cases for the adopted standard of

each product class are also shown in Tables EA.16 through EA.18. The differences between the

reference and sensitivity cases are due to changes in the macroeconomic assumptions of NEMSBT.

Reference Economic Growth

Table EA.11 Liquid Immersed Power Sector Emissions

NEMS-BT Results

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 2035 2038

AEO 2006 Reference Case with TM Y System Load

CO2 (Mt/a)13 2537.0 2672.0 2848.0 3038.0 3334.0 Extrapolation

Trial Standard Level

1.0 CO2 (Mt/a) 2537.0 2670.3 2845.1 3036.2 3325.9 0 -1.7 -2.9 -1.8 -8.1 -8.1 -8.1

2.0 CO2 (Mt/a) 2537.0 2669.6 2843.9 3035.5 3322.6 0 -2.4 -4.1 -2.5 -11.4 -11.4 -11.4

3.0 CO2 (Mt/a) 2537.0 2668.6 2842.2 3034.4 3318.0 0 -3.4 -5.8 -3.6 -16.0 -16.0 -16.0

4.0 CO2 (Mt/a) 2537.0 2668.3 2841.6 3034.1 3316.5 0 -3.7 -6.4 -3.9 -17.5 -17.5 -17.5

5.0 CO2 (Mt/a) 2537.0 2665.7 2837.1 3031.3 3304.1 0 -6.3 -10.9 -6.7 -29.9 -29.9 -29.9

6.0 CO2 (Mt/a) 2537.0 2662.8 2832.2 3028.3 3290.6 0 -9.2 -15.8 -9.7 -43.4 -43.3 -43.3

A CO2 (Mt/a) 2537.0 2667.0 2839.3 3032.7 3310.2 0 -5.0 -8.7 -5.3 -23.8 -23.8 -23.8

B CO2 (Mt/a) 2537.0 2668.6 2842.1 3034.4 3317.8 0 -3.4 -5.9 -3.6 -16.2 -16.2 -16.2

C CO2 (Mt/a) 2537.0 2668.8 2842.4 3034.6 3318.7 0 -3.2 -5.6 -3.4 -15.3 -15.3 -15.3

D CO2 (Mt/a) 2537.0 2669.3 2843.3 3035.1 3321.2 0 -2.7 -4.7 -2.9 -12.8 -12.8 -12.8

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons
EA-22

Table EA.12 Dry Type Power Sector Emissions

NEMS-BT Results

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 2035 2038

AEO 2006 Reference Case with TM Y System Load

CO2 (Mt/a)13 2537.0 2672.0 2848.0 3038.0 3334.0 Extrapolation

Trial Standard Level

1 CO2 (Mt/a) 2537.0 2671.9 2847.9 3037.9 3333.6 0.0 -0.1 -0.1 -0.1 -0.4 -0.4 -0.4

2 CO2 (Mt/a) 2537.0 2671.8 2847.7 3037.8 3333.2 0.0 -0.2 -0.3 -0.2 -0.8 -0.8 -0.8

3 CO2 (Mt/a) 2537.0 2671.8 2847.6 3037.8 3332.9 0.0 -0.2 -0.4 -0.2 -1.1 -1.1 -1.1

4 CO2 (Mt/a) 2537.0 2671.6 2847.3 3037.6 3332.0 0.0 -0.3 -0.6 -0.4 -1.6 -1.6 -1.6

5 CO2 (Mt/a) 2537.0 2671.5 2847.1 3037.5 3331.6 0.0 -0.5 -0.9 -0.5 -2.4 -2.4 -2.4

6 CO2 (Mt/a) 2537.0 2671.5 2847.1 3037.5 3331.6 0.0 -0.5 -0.9 -0.5 -2.4 -2.4 -2.4

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons

Low Economic Growth Power Sector Emissions

Table EA.13 Liquid Immersed Low Economic Growth Power Sector Emissions

NEMS-BT Results

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 2035 2038

AEO 2006 Low Growth Case with TM Y System Load

CO2 (Mt/a)1,3 2491.0 2601.0 2711.0 2828.0 2989.0 Extrapolation

Trial Standard Level

1 CO2 (Mt/a) 2491.0 2599.9 2709.0 2824.8 2984.7 0.0 -1.1 -2.0 -3.2 -4.3 -4.3 -4.3

2 CO2 (Mt/a) 2491.0 2599.4 2708.2 2823.5 2983.0 0.0 -1.6 -2.8 -4.5 -6.0 -6.0 -6.0

3 CO2 (Mt/a) 2491.0 2598.8 2707.1 2821.7 2980.5 0.0 -2.2 -3.9 -6.3 -8.5 -8.5 -8.5

4 CO2 (Mt/a) 2491.0 2598.6 2706.7 2821.1 2979.7 0.0 -2.4 -4.3 -6.9 -9.3 -9.3 -9.3

5 CO2 (Mt/a) 2491.0 2596.9 2703.7 2816.3 2973.1 0.0 -4.1 -7.3 -11.7 -15.9 -15.9 -15.9

6 CO2 (Mt/a) 2491.0 2595.0 2700.4 2811.0 2965.9 0.0 -6.0 -10.6 -17.0 -23.1 -23.0 -23.0

A CO2 (Mt/a) 2491.0 2597.7 2705.2 2818.7 2976.4 0.0 -3.3 -5.8 -9.3 -12.6 -12.6 -12.6

B CO2 (Mt/a) 2491.0 2598.8 2707.1 2821.7 2980.4 0.0 -2.2 -3.9 -6.3 -8.6 -8.6 -8.6

C CO2 (Mt/a) 2491.0 2598.9 2707.3 2822.0 2980.9 0.0 -2.1 -3.7 -6.0 -8.1 -8.1 -8.1

D CO2 (Mt/a) 2491.0 2599.2 2707.9 2823.0 2982.2 0.0 -1.8 -3.1 -5.0 -6.8 -6.8 -6.8

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons
EA-23

Table EA.14 Dry Type Low Economic Growth Power Sector Emissions

NEMS-BT Results

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 2035 2038

AEO 2006 Low Growth Case with TM Y System Load

CO2 (Mt/a)1,3 2491.0 2601.0 2711.0 2828.0 2989.0 Extrapolation

Trial Standard Level

1 CO2 (Mt/a) 2491.0 2600.9 2710.9 2827.9 2988.8 0.0 -0.1 -0.1 -0.1 -0.2 -0.2 -0.2

2 CO2 (Mt/a) 2491.0 2600.9 2710.8 2827.7 2988.6 0.0 -0.1 -0.2 -0.3 -0.4 -0.4 -0.4

3 CO2 (Mt/a) 2491.0 2600.8 2710.7 2827.6 2988.4 0.0 -0.2 -0.3 -0.4 -0.6 -0.6 -0.6

4 CO2 (Mt/a) 2491.0 2600.7 2710.5 2827.2 2988.0 0.0 -0.2 -0.4 -0.6 -0.8 -0.8 -0.8

5 CO2 (Mt/a) 2491.0 2600.7 2710.4 2827.1 2987.7 0.0 -0.3 -0.6 -0.9 -1.3 -1.3 -1.3

6 CO2 (Mt/a) 2491.0 2600.7 2710.4 2827.1 2987.7 0.0 -0.3 -0.6 -0.9 -1.3 -1.3 -1.3

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons

High Economic Growth Power Sector Emissions

Table EA.15 Liquid Immersed High Economic Growth Power Sector Emissions

NEMS-BT Results

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 2035 2038

AEO 2006 High Growth Case with TM Y System Load

CO2 (Mt/a)1,3 2586.0 2764.0 3041.0 3339.0 3697.0 Extrapolation

Trial Standard Level

1 CO2 (Mt/a) 2586.0 2762.1 3035.9 3333.2 3688.3 0.0 -1.9 -5.1 -5.8 -8.7 -8.7 -8.7

2 CO2 (Mt/a) 2586.0 2761.4 3033.8 3330.8 3684.8 0.0 -2.6 -7.2 -8.2 -12.2 -12.2 -12.2

3 CO2 (Mt/a) 2586.0 2760.3 3030.8 3327.5 3679.8 0.0 -3.7 -10.2 -11.5 -17.2 -17.2 -17.2

4 CO2 (Mt/a) 2586.0 2759.9 3029.9 3326.4 3678.2 0.0 -4.1 -11.1 -12.6 -18.8 -18.8 -18.8

5 CO2 (Mt/a) 2586.0 2757.1 3022.0 3317.5 3664.9 0.0 -6.9 -19.0 -21.5 -32.1 -32.0 -32.0

6 CO2 (Mt/a) 2586.0 2753.9 3013.4 3307.8 3650.5 0.0 -10.1 -27.6 -31.2 -46.5 -46.5 -46.5

A CO2 (Mt/a) 2586.0 2758.5 3025.9 3321.9 3671.5 0.0 -5.5 -15.1 -17.1 -25.5 -25.5 -25.5

B CO2 (Mt/a) 2586.0 2760.3 3030.7 3327.4 3679.6 0.0 -3.7 -10.3 -11.6 -17.4 -17.4 -17.4

C CO2 (Mt/a) 2586.0 2760.5 3031.3 3328.0 3680.6 0.0 -3.5 -9.7 -11.0 -16.4 -16.4 -16.4

D CO2 (Mt/a) 2586.0 2761.0 3032.9 3329.8 3683.2 0.0 -3.0 -8.1 -9.2 -13.8 -13.8 -13.8

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons
EA-24

Table EA.16 Dry Type High Economic Growth Power Sector Emissions

NEMS-BT Results

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 2035 2038

AEO 2006 High Growth Case with TM Y System Load

CO2 (Mt/a)1,3 2586.0 2764.0 3041.0 3339.0 3697.0 Extrapolation

Trial Standard Level

1 CO2 (Mt/a) 2586.0 2763.9 3040.8 3338.7 3696.6 0.0 -0.1 -0.2 -0.3 -0.4 -0.4 -0.4

2 CO2 (Mt/a) 2586.0 2763.8 3040.5 3338.4 3696.2 0.0 -0.2 -0.5 -0.6 -0.8 -0.8 -0.8

3 CO2 (Mt/a) 2586.0 2763.7 3040.3 3338.2 3695.8 0.0 -0.3 -0.7 -0.8 -1.2 -1.2 -1.2

4 CO2 (Mt/a) 2586.0 2763.5 3039.7 3337.6 3694.9 0.0 -0.4 -1.0 -1.2 -1.7 -1.7 -1.7

5 CO2 (Mt/a) 2586.0 2763.4 3039.5 3337.3 3694.4 0.0 -0.6 -1.5 -1.7 -2.6 -2.6 -2.6

6 CO2 (Mt/a) 2586.0 2763.4 3039.5 3337.3 3694.4 0.0 -0.6 -1.5 -1.7 -2.6 -2.6 -2.6

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons

Cumulative Power Sector Emission Impacts

Table EA.17 Cumulative Power Sector Emissions Impacts for Liquid-Immersed

Transformers

Trial

Standard

Level Emission

Reference Low Economic Growth High Economic Growth

2000-2030 2000-2038 2000-2030 2000-2038 2000-2030 2000-2038

1 CO2 (Mt/a) -60.9 -125.7 -47.1 -81.6 -88.2 -157.7

2 CO2 (Mt/a) -85.5 -176.4 -66.2 -114.5 -123.8 -221.3

3 CO2 (Mt/a) -120.4 -248.4 -93.2 -161.2 -174.3 -311.7

4 CO2 (Mt/a) -131.8 -271.9 -102.0 -176.5 -190.8 -341.1

5 CO2 (Mt/a) -225.1 -464.0 -174.2 -301.2 -325.8 -582.1

6 CO2 (Mt/a) -326.8 -673.6 -252.9 -437.2 -473.0 -845.0

A CO2 (Mt/a) -179.0 -369.2 -138.5 -239.6 -259.1 -463.2

B CO2 (Mt/a) -121.7 -251.1 -94.2 -163.0 -176.2 -315.0

C CO2 (Mt/a) -115.1 -237.6 -89.1 -154.2 -166.7 -298.0

D CO2 (Mt/a) -96.6 -199.3 -74.7 -129.4 -139.8 -250.0

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons

Table EA.18 Cumulative Power Sector Emissions Impacts for Dry-Type Transformers

Trial

Standard

Level

Emission

Reference Low Economic Growth High Economic Growth

2000-2030 2000-2038 2000-2030 2000-2038 2000-2030 2000-2038

1 CO2 (Mt/a) -2.8 -5.8 -2.2 -3.8 -4.1 -7.4

2 CO2 (Mt/a) -5.7 -11.8 -4.4 -7.6 -8.4 -15.0

3 CO2 (Mt/a) -8.3 -17.1 -6.4 -11.0 -12.0 -21.6

4 CO2 (Mt/a) -12.0 -24.8 -9.2 -16.0 -17.5 -31.4

5 CO2 (Mt/a) -17.9 -36.9 -13.7 -23.8 -26.0 -46.7

6 CO2 (Mt/a) -17.9 -36.9 -13.7 -23.8 -26.0 -46.7

1Comparable to Table A17 of AEO2006: Electric Generators

2Comparable to Table A8 of AEO2006: Emissions

3All results in metric tons (t), equivalent to 1.1 short tons
EA-25

5.1.2 Discounted Emissions

Table EA.19 provides DOE’s estimate of cumulative power sector CO2 for an uncapped

emissions scenario for the TSLs considered in this rulemaking. Because of the Clean Air

Interstate Rule (CAIR), which the EPA issued on March 10, 2005, will permanently cap

emissions of NOX in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12,

2005). As with sulfur dioxide emissions, for which a cap was previously in place, a cap on NOX

emissions means that equipment efficiency standards may have no physical effect on these

emissions. Similarly emissions of Hg for the power sector are also subject to emissions caps

during the evaluation period, so that distribution transformer standards may similarly result in no

physical effect on these emissions. DOE evaluated the emissions forecasts from AEO2006 and

found that because of these new regulations capped most power sector NOX and Hg emissions,

decreasing energy use from the adopted standard would not have any physical emissions reduction

effects. The economic effects of emissions reductions are included in the forecasted projection of

electricity prices and thus are included in DOE’s NPV analysis, but are not reported separately.

DOE also calculated discounted values for future emissions, using the same seven-percent

and three-percent real discount rates that it used in calculating the NPV. Table EA.19 also shows

the discounted cumulative emissions impacts for both liquid-immersed and dry-type, mediumvoltage transformers. 

Table EA.19 Discounted CO2 Emissions Reductions of the Trial Standard Levels by

Design Line (in millions of metric tons)

Distribution

Transformers

Discount

Rate %

Trial Standard Level

1 (TP 1) 2 3 4 5 6 A B C D

Liquid-Immersed

0 125 176 248 272 464 674 369 251 238 199

3 62 87 123 135 230 334 183 124 118 99

7 27 38 53 59 100 145 80 54 51 43

Dry-Type

0 5.8 11.8 17.1 24.8 36.9 36.9

3 2.9 5.8 8.5 12.3 18.3 18.3

7 1.2 2.5 3.7 5.3 8.0 8.0
EA-26

5.1.3 Fuel-Cycle Emissions

As discussed earlier, fuel-cycle emissions refer to the emissions associated with the

amount of fuel used in the upstream production of electricity and downstream consumption of

electricity, including energy used at the power plant. The amount of energy used to perform the

upstream processes, such as natural gas production, is not linked to the downstream consumption

of electricity attributed to natural gas. For this reason, changes in upstream emissions due to

adopted standards are not counted in NEMS-BT. Although DOE does not report actual

estimates of the effects of standards on upstream emissions, the emissions factors described here

provide the reader with a sense of the possible magnitude of the effects. 

Estimates of upstream emissions for CO2 and NOx are taken from a study in 1993 by Mark

A. DeLuchi (sometimes spelled DeLucci), Ph. D., at Argonne National Laboratory. Dr. DeLuchi

provides estimates of full fuel-cycle emissions factors for CO2, CH4, carbon monoxide (CO), nonmethane organic compounds (NMOC), and NOx

 from coal and natural gas production.10 The

emission factor for SO2 is taken from the EPA Report AP-42, Compilation of Air Pollutant

Emission Factors.

11 The EPA AP-42 report notes that coal-cleaning is the primary source for

upstream SO2 emissions from coal production, so the emission factor for SO2 reflects only the

coal-cleaning process. Transportation of coal is not addressed in EPA’s study.

Emission factor estimates and corresponding percentages of contributions of upstream

emissions from coal and natural gas production, relative to power plant emissions, are shown in

Table EA.20 for CO2, SO2, and NOx. The percentage relative to power plant emissions provides

a means to estimate upstream emission savings based on the savings from the power plant. The

values shown in Table EA.20 represent emissions from upstream processes as mass (g) per

deliverable energy to end-use consumers, in gigajoules (GJ).

Table EA.20 Estimated Upstream Emission Factors and Corresponding Percentages of

Direct Power Plant Combustion Emissions

Coal Natural Gas

Emission

Factor (g/GJ)

% of Combustion

Emissions

Emission Factor 

(g/GJ)

% of Combustion

Emissions

CO2 8,147 2.7 20,000 11.9

SO2 29.2 0.9 0 0

NOx 41.7 5.8 153 40

Relative to the entire fuel cycle, Dr. DeLuchi estimates that approximately eight percent,

by mass, of emissions from coal production are due to mining, preparation that includes cleaning

the coal, and transportation from the mine to the power plant. Transportation emissions include

emissions from the fuel used by the mode of transportation that moves the coal from the mine to

the power plant. Also, Dr. DeLuchi estimates that approximately 14 percent of emissions from
EA-27

natural gas production result from upstream processes. In view of Table EA.20, this higher loss

factor in natural gas production, compared to the emissions factor for coal, is likely due to the

higher NOx contribution. In sum, emissions factors relative to power plant emissions are a

relatively small proportion of the energy losses attributable to upstream processes. With the

exception of NOx emissions from natural gas production, upstream emissions are less than 12

percent of power plant emissions.

5.2 Wetlands / Endangered and Threatened Species / Cultural Resources

DOE’s adopted action is not site-specific, nor would it impact land disturbance or use due

to distribution transformer placement. Therefore, this action is not expected to affect the quality

of wetlands, or threatened or endangered species. Further, this action is not expected to impact

cultural resources such as historical or archaeological sites. 

5.3 Socioeconomic Impacts 

DOE's analysis has shown that the increase in the first cost of purchasing a more efficient

distribution transformer at the adopted and alternative standard levels is offset by a reduction in

the LCC of owning a more efficient piece of equipment. Although the adopted and alternative

standards increase the first cost, the standard levels result in a decrease in LCC (due to reduced

energy costs) for many consumers. The precise change in LCC varies by standard level, size, class

of transformer, and type of customer. At the adopted standard level, approximately 75 percent of

the market is either not affected or realizes LCC savings. For a complete discussion of the LCC

impacts on consumers, see Chapter 8 of the TSD

5.4 Environmental Justice Impacts 

According to Executive Order 12898 of February 11, 1994, “Federal Actions to Address

Environmental Justice in Minority Populations and Low-Income Populations,” DOE is required to

examine the effect of more stringent energy-efficiency standards on (1) small businesses that

either manufacture or use distribution transformers, (2) manufacturers of niche products related to

distribution transformers, and (3) small businesses operated by disadvantaged or minority

populations.

Regarding users of distribution transformers, small businesses are included as part of the

overall population examined by DOE in the LCC analysis. The results of that analysis estimated

that between 25 and 62 percent of distribution transformer customers would experience positive

economic impacts from the adopted standard. 
a

 Small Business Administration -http://www.sba.gov/gopher/Financial-Assistance/Defin/defi4.txt (06/24/05)

EA-28

Small distribution transformer manufacturing enterprises, as defined by the Small Business

Administration, are those with no more than 750 employees.a DOE identified and interviewed six

small manufacturers of distribution transformers, five of which produce medium-voltage, dry-type

transformers and one of which produces liquid-immersed transformers. Because the liquidimmersed distribution transformer industry largely produces customized transformers, small

businesses can compete because each unique design is produced in relatively small volumes for a

given order. Implementation of an energy conservation standard would have a relatively minor

differential impact on small manufacturers of liquid-immersed distribution transformers. 

Because of the potential impacts of a standard on manufacturers of the medium-voltage,

dry-type superclass, DOE determined that it cannot certify that the adopted rule (TSL2), if

promulgated, would have no significant economic impact on a substantial number of small

entities. Because DOE cannot certify this, due to the potential impacts on medium-voltage, drytype manufacturers, it prepared an initial regulatory flexibility analysis (IRFA) for this rulemaking,

which can be found in section VI.B of the NOPR. For additional information on this subject, see

also section V.B.2.b of the NOPR (71 FR 44356-44408) and the manufacturer impact analysis

(MIA) in Chapter 12 of the TSD.

DOE did not conduct a separate analysis to assess the impacts of a new standard on niche

product manufacturers because it found no niche products for which the adoption of a new

standard would raise special considerations.

DOE's LCC subgroup analysis (TSD Chapter 11) did not include small or disadvantaged

businesses or populations as a subgroup. However, DOE believes that there are no

disproportionately high and adverse human health or environmental effects on small businesses,

minority populations, and low-income populations resulting from more stringent energy-efficiency

standards. Positive impacts, such as decreased air emissions, would be equally shared among all

populations.

The MIA (TSD Chapter 12), and the regulatory impact analysis (published with the TSD)

examined impacts on various business populations. However, DOE received no data concerning

differential impacts on businesses owned by minority or disadvantaged populations. DOE

requests comment on this issue.

5.5 Energy Consumption Impacts

The adopted standard levels for distribution transformers (TSL C for liquid-immersed and

TSL 2 for medium-voltage, dry-type) would result in the national energy savings shown in Table

EA.21 and EA.22. Energy savings for the other TSLs are also provided.
EA-29

5.6 Noise and Aesthetics

The adopted action is not likely to affect the sound power levels or sound quality levels

associated with distribution transformers. Transformers have no moving parts but do often emit a

buzz associated with 60-Hz alternating current. DOE’s adopted standard is not expected to

materially affect the noise of transformers. Higher-efficiency transformers tend to be larger;

however, the efficiencies selected by DOE will not result in significant changes in transformer size

nor in any other aesthetic feature. In sum, the noise and aesthetics of the more efficient

distribution transformers covered under this EA would be virtually no different from equipment

being installed today.

5.7 Summary of Environmental Impacts

Tables EA.22 to EA.24 provide a summary of the analysis results by superclass to aid the

reader in the discussion of the benefits and burdens for the different TSLs as well as the no-action

alternative.

Table EA.21 Summary of the Analysis Results for Liquid-Immersed Transformers

No

Action

Trial Standard Level

1 2 3 4 5 6 A B C D

Cumulative Emission Reductions*

CO2 Equivalent (Mt) 0.0 125 176 248 272 464 674 369 251 238 199

Cumulative Primary Energy

Saved (quads)* 0.0 1.38 1.94 2.76 3.00 5.07 7.37 4.07 2.75 2.61 2.18

Socioeconomic Impacts – All Consumers

Transformers with nonnegative LCC savings (%)

based on underlying DLs 

NA

87.9

to

98.6

79.3

to

98.6

81.1

to

98.0

55.7

to

87.6

15.2

to

42.3

0.5 

to

15.2

20.4

to

67.6

57.5

to

91.9

57.5

to

97.5

79.3

to

98.6

Payback periods (years), based

on underlying DLs NA 2.3 to7.8

2.4 to

10.4

2.4 to

11.4

7.8 to

11.4

19.3

to

23.4

21.6

to

52.1

10.6

to

24.7

8.9 to

15.7

4.3 to

15.7

3.6 to

10.4

Environmental Justice Impacts None None None None None None None None None None None

Wetlands/Endangered and

Threatened Species/Cultural

Resources Impacts

None None None None None None None None None None None

Fuel-Cycle (Upstream) Emissions

Impacts None **   **  **   **  ** **

Noise and Aesthetics Impacts None None None None None None None None None None None

* Cumulative total is over a time period starting in 2010 and ending in 2038.

** DOE does not report actual estimates of the effects of standards on upstream emissions, but section 5.1.2

above provides a sense of the possible magnitude of effects.
EA-30

Table EA.22 Summary of the Analysis Results for Dry-Type, Medium-Voltage

Transformers 

No

Action

Trial Standard Level

1

2

(Adopted

Action)

3 4 5 6

Cumulative Emission Reductions*

 CO2 Equivalent (Mt) 0.0 5.8 11.8 17.1 24.8 36.9 36.9

Cumulative Primary Energy Saved

(quads)* 0.0 0.06 0.13 0.19 0.27 0.40 0.40

Socioeconomic Impacts – All

Consumers

Transformers with non-negative

LCC savings (%) based on

underlying DLs

NA 96.7 to

99.7

84.4 to

98.7

81.5 to

92.6

54.0 to

75.8

21.9 to

63.5

21.9 to

63.5

Payback periods (years), based on

underlying DLs NA 0.5 to5.0 1.8 to 6.4 3.4 to7.0 5.9 to 9.6 7.8 to18.7

7.8 to

18.7

Environmental Justice Impacts None None None None None None None

Wetlands/Endangered and Threatened

Species/Cultural Resources Impacts None None None None None None None

Fuel-Cycle (Upstream) Emissions

Impacts None **   **  ** **

Noise and Aesthetics Impacts None None None None None None None

* Cumulative total is over a time period starting in 2010 and ending in 2038.

** DOE does not report actual estimates of the effects of standards on upstream emissions, but section 5.1.2

above provides a sense of the possible magnitude of effects.

DOE has adopted energy-efficiency standards for distribution transformers at TSL C for

liquid-immersed transformers and TSL 2 for medium-voltage, dry-type transformers. The

adopted standards would apply to all covered products offered for sale in the United States and its

Territories, with a compliance date of January 1, 2010. The justification for selecting the adopted

action, adopting these standard levels over the other TSLs considered, is fully explained in the

final rule. The final rule is available on the internet at: 

http://www.eere.energy.gov/buildings/appliance_standards/commercial/distribution_transformers.

html under “Final Rule.”

In addition to reducing the secondary energy lost in the distribution transformers

themselves, the adopted standards would save even more energy at the electric power plant

source, where less primary energy (e.g., oil, coal, or natural gas) directly attributable to the losses

from distribution transformers would be burned. Burning less oil, coal, or natural gas reduces

greenhouse gas emissions and pollutants, creating a cleaner environment. 
EA-31

In the 28-year period after the new standards become effective, the Nation will save about

2.74 quadrillion British thermal units (quads) of primary energy. Additionally, these energy

savings would significantly reduce emissions of air pollutants and greenhouse gases associated

with electricity production, by 250 Mt of CO2. This is equivalent to all the energy consumed by

27 million American households in a single year. Furthermore, the adopted standards would

eliminate the need for construction of roughly six new 400-megawatt (MW) power plants by

2038. 
EA-32

REFERENCES

1. Barnes, P. R., J. W. Van Dyke, B. W. McConnell, and S. Das. Determination Analysis of

Energy Conservation Standards for Distribution Transformers. 1996. Oak Ridge National

Laboratory. Oak Ridge, TN. Report No. ORNL-6847. 

2. Barnes, P. R., S. Das, B. W. McConnell, and J. W. Van Dyke. Supplement to the

"Determination Analysis" (ORNL-6847) and Analysis of the NEMA Efficiency Standards

for Distribution Transformers. 1997. Oak Ridge National Laboratory. Oak Ridge, TN.

Report No. ORNL-6925. 

3. National Electrical Manufacturers Association. NEMA Standards Publication TP 1-1996;

Guide for Determining Energy Efficiency for Distribution Transformers. 1996. National

Electrical Manufacturers Association. Rosslyn, VA. Report No. TP 1-1996. 

4. U.S. Department of Energy-Office of Building Technologies. Technical Support

Document: Energy Conservation Program for Commercial and Industrial Equipment:

Electrical Distribution Transformers - ANOPR Version. 2004. U.S. Department of

Energy. Washington, DC. Report No. LBNL-53985.

<http://www.eere.energy.gov/buildings/appliance_standards/commercial/dist_trans_tsd_0

61404.html>

5. U.S. Department of Energy-Office of Building Technologies. Technical Support

Document: Energy Conservation Program for Commercial and Industrial Equipment:

Electrical Distribution Transformers - NOPR Version. 2005. U.S. Department of Energy.

Washington, DC.

<http://www.eere.energy.gov/buildings/appliance_standards/commercial/distribution_trans

formers.html>

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2005: With Projections Through 2025. January, 2005. Washington, DC. Report No.

DOE/EIA-0383(2005). <http://www.eia.doe.gov/oiaf/aeo/index.html>

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Gases in the United States 2003. December, 2004. Washington, DC. Report No.

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8. U.S. Office of Management and Budget. Circular A-4: Regulatory Analysis. 2003. (Last

accessed March 25, 2005.) This material is available in Docket #86. Contact Ms. Brenda

Edwards-Jones, U.S. Department of Energy, Building Technologies Program, Mailstop

EE-2J, 1000 Independence Avenue, SW, Washington, DC, 20585-0121, telephone (202)

586-2945 for more information. <http://www.whitehouse.gov/omb/circulars/a004/a4.pdf>
EA-33

9. Lind, R. C., K. J. Arrow, G. R. Corey, P. Dasgupta, A. K. Sen, T. Stauffer, J. E. Stiglitz,

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(Last accessed July 25, 2005.) This material is available in Docket #86. Contact Ms.

Brenda Edwards-Jones, U.S. Department of Energy, Building Technologies Program,

Mailstop EE-2J, 1000 Independence Avenue, SW, Washington, DC, 20585-0121,

telephone (202) 586-2945 for more information.

<http://www.epa.gov/ttn/chief/ap42/ch03/index.html>