1 | Building Technologies Program eere.energy.gov The Parker Ranch installation in Hawaii 

# BUILDING TECHNOLOGIES PROGRAM

Distribution Transformers Energy Conservation Program Preliminary Analysis James Raba U.S. Department of Energy Energy Efficiency & Renewable Energy Jim.Raba@ee.doe.gov April 5, 20112 | Building Technologies Program eere.energy.gov 

### • Introductions 

### • Role of the Facilitator • Ground Rules (norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– Focus on issues, not personalities

– One person speak at a time (raise hand to be recognized; state your name for the record)

– Set cell phones to silent/vibrate 

### • Housekeeping Items 

### • Agenda Review • Opening Remarks 

# Welcome and Introduction3 | Building Technologies Program eere.energy.gov 

# Morning Agenda 9:00 – 9:05 am Welcome 9:05 – 9:20 am Introductions, Agenda Review, and Opening Statements 9:20 – 9:25 am Regulatory History 9:25 – 9:30 am Rulemaking Overview and Scope of Coverage 9:30 – 10:00 am Test Procedure 10:00 – 10:15 am Break 10:15 – 11:00 am Market and Technology Assessment and Screening Analysis 11:00 – 12:00 pm Engineering Analysis 12:00 – 1:00 pm Lunch4 | Building Technologies Program eere.energy.gov 

# Afternoon Agenda 1:00 – 1:15 pm Markups for Product Price Determination 1:15 – 1:45 pm Energy Use and End - Use Load Characterization 1:45 – 2:15 pm Life - Cycle Cost and Payback Period Analysis 2:15 – 2:45 pm Shipments and National Impacts Analysis 2:45 – 3:00 pm Break 3:00 – 3:15 pm Preliminary Manufacturer Impact Analysis 3:15 – 3:30 pm NOPR Analyses 3:30 – 4:00 pm Closing Remarks5 | Building Technologies Program eere.energy.gov 

### Markup Analysis; Energy Use & End - Use Load National Impact Analysis 

# Public Meeting Agenda

1 Overview

4 2 

### 3 Market & Tech; Screening; Engineering

6 5 Test Procedure

Life- Cycle Cost and Payback Period Analysis 7 Preliminary MIA; NOPR Analyses6 | Building Technologies Program eere.energy.gov 

### • Present the procedural and analytical approaches to evaluate energy conservation standards for distribution transformers.



### • Provide a forum for public discussion of rulemaking issues.

• Encourage interested parties to submit data, information, and written 

### comments.

• Inform interested parties and facilitate the rulemaking process. 

# Purpose of the Preliminary Analysis Public Meeting7 | Building Technologies Program eere.energy.gov 

# Issues for Comment

Issue Box The Department welcomes comments, data, and information regarding distribution transformer energy 

### conservation standards. Throughout this presentation, specific issues will be raised for discussion on slides such as this , with identifying numbers corresponding to issues for comment from section three in the executive 

### summary of the preliminary TSD. Nonetheless , comments concerning any part of the document or presentation are welcome.8 | Building Technologies Program eere.energy.gov 

### • In all correspondence, please refer to the Distribution Transformers 

### rulemaking by:

– Distribution Transformers Rulemaking,

– Docket Number EE –2010– BT–STD–0048 , and

– Regulatory Identification Number (RIN) 1904–AC04


### • Email : DistributionTransformers - 2010 - STD - 0048@ee.doe.gov

• Comment period closes: April 18, 2011 

# Feedback Is Requested

Postal : Hand Delivery/Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE - 2J 1000 Independence Avenue, SW Washington, DC 20585 - 0121 Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Suite 600 950 L‘Enfant Plaza, SW Washington, DC 20024 Tel: 202 - 586 - 29459 | Building Technologies Program eere.energy.gov 

# Regulatory History

• Title III, Part C of the Energy Policy and Conservation Act of 1975 (EPCA) (Public Law 94 - 

### 163 ) established the ―Energy Conservation Program for Certain Industrial Equipment,‖ including distribution transformers.

• Energy Policy Act (EPACT) of 1992 (Public Law 102 - 486) directed DOE to establish energy conservation standards for distribution transformers.

• EPACT 2005 set standards for low -voltage dry- type (LVDT) distribution transformers at the NEMA TP 1 - 2002 level.10 | Building Technologies Program eere.energy.gov 

### • October 2007 – DOE issued a Final Rule establishing energy conservation standards for liquid - immersed and medium -voltage dry- type (MVDT) distribution transformers. (72 FR 58190)

• As a result of a settlement agreement, DOE has an expedited timeline to 

### determine whether to amend standards for liquid - immersed and MVDT distribution transformers.

• DOE must publish by October 1, 2011 either:

– A determination that the standards do not need to be amended, or

– A Notice of Proposed Rulemaking (NOPR) including any proposed standards.



### • If DOE publishes a NOPR, it must publish a Final Rule by October 1, 2012. 

# Regulatory History (Continued)11 | Building Technologies Program eere.energy.gov 

# Regulatory History (Continued) Test Procedure

• On April 27, 2006, DOE codified a test procedure final rule for distribution 

### transformers in 10 CFR Part 431, Appendix A to Subpart K, ―Uniform Test Method for Measuring the Energy Consumption of Distribution Transformers.‖ 71 FR 24972

– Based on NEMA TP 2 - 1998.



## • The Energy Independence and Security Act 2007 (EISA) requires that DOE amend each test procedure within seven years of its original publication. (42 U.S.C. 6314(a)(1))



## • DOE also intends to review its test procedure concurrently with the energy conservation standards.12 | Building Technologies Program eere.energy.gov 

# EPCA Factors 42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors when 

### setting energy conservation standards for distribution transformers:

EPCA Factors DOE Analysis 1. Economic impact on consumers and manufacturers Life - Cycle Cost Analysis Manufacturer Impact Analysis 2. Lifetime operating cost savings compared to increased cost for the product Life - Cycle Cost Analysis 3. Total projected energy savings National Impact Analysis 4. Impact on utility or performance Engineering Analysis Screening Analysis 5. Impact of any lessening of competition Manufacturer Impact Analysis 6. Need for national energy conservation National Impact Analysis 7. Other factors the Secretary considers relevant Environmental Assessment Utility Impact Analysis Employment Impact Analysis13 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule
Market & Technology Assessment Screening Analysis Engineering

Analysis Energy Use and

End - Use Load Characterization Shipments Analysis National Impact Analysis Markups for Product Price Determination Life - Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis Compliance Date14 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date15 | Building Technologies Program eere.energy.gov 

# Analyses for Final Rule

Framework Document NOPR Final Rule

Revise NOPR Analyses Preliminary Analysis16 | Building Technologies Program eere.energy.gov 

# Distribution Transformers Rulemaking Schedule

2011 2014

2012 2013 2015 2016

Milestone Date Federal Register Notice of Public Meeting and Availability of the Preliminary Technical Support Document March 2, 2011 Issue NOPR or Determination October 2011 Issue Final Rule October 2012 Compliance Date January 201617 | Building Technologies Program eere.energy.gov 

# Distribution Transformers Rulemaking Schedule

Issue: The Department welcomes comment on the time necessary for the industry to implement amended energy conservation standards if DOE chooses to amend standards. Specifically, would a compliance date prior to 

### January 1, 2016 be feasible, and if not, why? • If DOE finds that amended standards are warranted, the compliance date 

### of any amended standards must be no later than January 1, 2016.

– DOE may select a compliance date prior to January 1, 2016.18 | Building Technologies Program eere.energy.gov 

## Rulemaking Scope and Current Efficiency Standards for Distribution Transformers Distribution Transformers Liquid Immersed 

### Dry- Type

Low - Voltage Dry- Type 

### Medium - Voltage Dry- Type BIL 20 - 45 BIL 46 - 95 BIL ≥96 (2007 Final Rule)
NEMA TP 1 - 2002

(EPACT 2005) (2007 Final Rule)19 | Building Technologies Program eere.energy.gov 

# Distribution Transformers Related Statutory Definitions

• EPACT 2005 presented the definition of a distribution transformer, and DOE refined the definition during the 2006 test procedure rulemaking. ( 71 FR 24972 )

• Under 10 CFR 431.192, the term 'distribution transformer' means a 

### transformer that:

– Has an input voltage of 34.5 kilovolts or less

– Has an output voltage of 600 volts or less;

– Is rated for operation at a frequency of 60 Hertz; and



### – Has a capacity of 10 kVA to 2500 kVA for liquid - immersed units and 15 kVA to 2500 kVA for dry-type units; but

– Is not an: a utotransformer, d rive (isolation) transformer, g rounding transformer, m achine -tool (control) transformer, n onventilated transformer, 

### rectifier transformer, regulating transformer, s ealed transformer, s pecial impedance transformer, t esting transformer, t ransformer with tap range of 20 percent or more, u ninterruptible power supply transformer, or w elding transformer.20 | Building Technologies Program eere.energy.gov 

# Distribution Transformers Related Statutory Definitions (Continued)

•  ̳Liquid - immersed distribution transformer‘ means a distribution transformer in which the core and coil assembly is immersed in an insulating liquid.

•  ̳Low-voltage dry- type (LVDT) distribution transformer‘ means a 

### distribution transformer that :

– has an input voltage of 600 volts or less;

– is air- cooled; and

– does not use oil as a coolant.


### •  ̳Medium -voltage dry- type (MVDT) distribution transformer‘ means a distribution transformer in which the core and coil assembly is immersed in a gaseous or dry compound insulating medium, and which has a 

### rated primary voltage between 601 V and 35 kV.21 | Building Technologies Program eere.energy.gov 

### Markup Analysis; Energy Use & End - Use Load National Impact Analysis 

# Public Meeting Agenda

1 Overview

4 2 

### 3 Market & Tech; Screening; Engineering

6 5 Test Procedure

Life- Cycle Cost and Payback Period Analysis 7 Preliminary MIA; NOPR Analyses22 | Building Technologies Program eere.energy.gov 

# Test Procedure Overview

• DOE published a test procedure (TP) final rule for distribution transformers on April 27, 2006. (71 FR 24972)

– Based on NEMA TP - 2 test procedure.

– Same TP for all three transformer types


### • The test procedure is codified in 1 0 CFR Part 431, Appendix A to Subpart K, ―Uniform Test Method for Measuring the Energy Consumption of Distribution Transformers.‖23 | Building Technologies Program eere.energy.gov 

# Test Procedure: Dual/Multiple - Voltage Secondaries

• Some transformers have secondary windings that can be connected either in series or in parallel.

• Reconfigurable secondaries are most commonly used in low kVA , single phase, liquid - immersed, pole - mounted units.

• The test procedure currently states that efficiency must be tested at voltage with highest losses, which is usually in parallel.



### • Some MVDT transformers may have different BIL ratings in different configurations.

• DOE proposes allowing manufacturers to meet amended energy conservation standards in any secondary configuration and at the lowest BIL.24 | Building Technologies Program eere.energy.gov 

# Test Procedure (Continued): Dual/Multiple - Voltage Secondaries Issue 1: DOE seeks comment on its proposal to amend the 

### test procedure to allow compliance testing in any secondary configuration. Should the proposed amendment apply to all covered distribution transformers or a subset of transformers? DOE welcomes the submission of any data 

### that would support a conclusion. Issue 3: DOE welcomes comment on its proposal to require 

### compliance at the lowest basic impulse levels (BILs) that a dual/multiple -voltage distribution transformer is rated for operation.25 | Building Technologies Program eere.energy.gov 

# Test Procedure (Continued): Other Topics of Interest

Issue 4 - DOE welcomes comment on all aspects of the current test procedure for distribution transformers. • Although DOE is considering allowing testing in any secondary configuration, primaries must still be tested in their highest loss configuration.

– Primaries exhibit larger differences in efficiency between the series and parallel configurations.



### • Currently, the reference loading points are:

– 50 percent for liquid - immersed and MVDT.

– 35 percent for LVDT.26 | Building Technologies Program eere.energy.gov 

### Markup Analysis; Energy Use & End - Use Load National Impact Analysis 

# Public Meeting Agenda

1 Overview

4 2 

### 3 Market & Tech; Screening; Engineering

6 5 Test Procedure

Life- Cycle Cost and Payback Period Analysis 7 Preliminary MIA; NOPR Analyses27 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Date

Screening Analysis Engineering

Analysis Energy Use and

End - Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Market & Technology Assessment

Preliminary

Manufacturer Impact Analysis Compliance Date28 | Building Technologies Program eere.energy.gov 

# Purpose

• Market and Technology Assessment

– Characterize the distribution transformer market and industry.

– Identify the technology options to improve distribution transformer efficiency.

– Establish equipment classes.



### • Screening Analysis

– Screen out technology options that DOE will not consider in the engineering analysis for distribution transformers based on several criteria.29 | Building Technologies Program eere.energy.gov 

## Relationship of Market and Technology Assessment to Other Analyses Market and Technology Assessment Equipment Classes Technology options to improve efficiency

Screening Analysis Design options to improve efficiency Engineering Analysis30 | Building Technologies Program eere.energy.gov 

# Equipment Classes

• DOE divides covered equipment into classes by:

– The Type of energy used,

– The Capacity, or

– Any performance - related features that affect consumer utility or efficiency.



### • DOE considered 10 equipment class groupings by dividing the population of distribution transformers based upon:

– Type of transformer insulation: liquid -immersed or dry

- type ,

– Number of phases: single or three ,

– Voltage class: low or medium (for dry - type units only) , and

– Basic impulse insulation level (BIL): (for MVDT units only) .31 | Building Technologies Program eere.energy.gov 

# Distribution Transformers Equipment Class Groupings There are 115 discrete kVA ratings across the ten equipment class groupings (ECG) ECG Insulation Phases Voltage BIL kVA Range 1 Liquid - Immersed Single Medium --- 10- 833 kVA 2 Liquid - Immersed Three Medium --- 15 -2500 kVA 3 Dry-Type Single Low --- 15 -333 kVA 4 Dry-Type Three Low --- 15 - 1000 kVA 5 Dry-Type Single Medium 20-45 kV BIL 15 - 833 kVA 6 Dry-Type Three Medium 20-45 kV BIL 15 -2500 kVA 7 Dry-Type Single Medium 46 -95 kV BIL 15 - 833 kVA 8 Dry-Type Three Medium 46 -95 kV BIL 15 -2500 kVA 9 Dry-Type Single Medium > 96 kV BIL 75 - 833 kVA 10 Dry-Type Three Medium > 96 kV BIL 225 -2500 kVA32 | Building Technologies Program eere.energy.gov 

# Distribution Transformers 2009 Industry Shipments

Equipment Class Grouping Units Shipped MVA



### Capacity Shipped 1. Liquid - immersed, medium -voltage, single - phase 683,726 21,994 2. Liquid - immersed, medium -voltage, three - phase 49,739 32,266 3. Dry-type, low-voltage, single - phase 17,740 647 4. Dry-type, low-voltage, three - phase 206,929 15,778 5. Dry-type, medium -voltage, single - phase, 20 - 45 kV BIL 709 23 6. Dry-type, medium -voltage, three - phase, 20 - 45 kV BIL 522 257 7. Dry-type, medium -voltage, single - phase, 46 - 95 kV BIL 546 23 8. Dry-type, medium -voltage, three - phase, 46 - 95 kV BIL 2,074 3,655 9. Dry-type, medium -voltage, single - phase, ≥ 96 kV BIL 202 9 10. Dry-type, medium -voltage, three - phase, ≥ 96 kV BIL 1,286 2,206 TOTAL 963,473 76,85833 | Building Technologies Program eere.energy.gov 

# Technology Options Technology Option Material / Concept Conductor Materials for Coils Aluminum (wire and sheet) Copper (wire and sheet) Core Materials Cold - Rolled High Silicon (CRHiSi) Steel CRHiSi Domain - Refined Steels Amorphous Materials in Wound Core Geometry Modifications Adjust the cross - sectional area of the 

### core/conductor, or adjust volts per turn Symmetric Core Designs Continuously wound cores with 120 degree radial symmetry for three - phase designs Core Deactivation Technology A transformer is replaced by three smaller transformers that are (de)activated in response to changes in load demand.34 | Building Technologies Program eere.energy.gov 

### • ―Symmetric Core‖ designs are three - phase designs that use a continuously wound core with 120 ° radial symmetry.

• Advantages include lowered: weight, 

### volume, no - load losses, noise, vibration, stray magnetic fields, inrush current, and power in the third harmonic.



### • Best suited for delta - delta or delta - wye connections, though zero - sequence fluxes associated with wye - wye connections can be mitigated by a delta - connected tertiary 

### winding. 

# Technology Assessment: Symmetric Core Designs

Source: Lundmark, Sonja. “Computer Model of Electromagnetic Phenomena in Hexaformer.” 2007. http://www.hexaformer.com/ExternaDokument/chalmers_re port1.pdf.35 | Building Technologies Program eere.energy.gov 

# Symmetric Core Designs: Request for Comment

Issue 5: DOE seeks comment on symmetric core designs, their practicability to manufacture and install, and whether they offer potential for efficiency improvement. In particular, DOE seeks comment on any 

### application types in which using a symmetric core design may be infeasible. DOE also seeks comment on any intellectual property concerns related to this technology and the feasibility of manufacturing it on a large scale.36 | Building Technologies Program eere.energy.gov 

### • Reduces core losses by using a system of smaller transformers to replace a single, larger transformer.

– Example: Three 25 kVA transformers in parallel replace a 75 kVA transformer.


### • Control unit can activate and deactivate component transformers depending on the loading demands.

– Optimizes combination of transformers at given load.


### • DOE is only aware of this technology in LVDT distribution transformers.

– Medium -voltage core deactivation systems have not been produced commercially, and pose difficulties for switching within the primary and 

### secondary connections.


### • Best suited for applications with low loading demands. 

# Technology Assessment: Core Deactivation Technology37 | Building Technologies Program eere.energy.gov 

# Core Deactivation Technology Load vs. Efficiency

This figure is for illustrative purposes only, and is not based on actual DOE research38 | Building Technologies Program eere.energy.gov 

### • While core deactivation technology could save energy over a load cycle, these energy savings may not be captured by the current test 

### procedure specifying a single load factor.
• A weighted - average loss calculation using various loadings could better capture this technology‘s energy savings potential. Example: 

# Technology Assessment: Core Deactivation Technology

Loading (%) Losses

(W) Single Loading Point,

Load Frequency (%) Weighted Average, Load Frequency (%) 0 200.0 0 31 15 222.5 0 22 35 322.5 100 20 50 450.0 0 18 75 762.5 0 9 Average Losses 322.5 322.539 | Building Technologies Program eere.energy.gov 

### • DOE did not analyze core deactivation technology for the preliminary analysis, but intends to analyze it for the NOPR.

– Scale each design to 1/3 its kVA and group them in sets of three.

– Account for additional cost and weight of the core deactivation technology.

– Analyze each core deactivation system using various loading scenarios.



### • Core deactivation systems using non - identical component transformers.

– Each component transformer requires a similar winding design to maintain impedance at each loading.



### • Based on conversations with manufacturers, core deactivation with MVDT has additional challenges. 

# Technology Assessment: Core Deactivation Technology40 | Building Technologies Program eere.energy.gov 

# Technology Assessment: Core Deactivation Technology

Issue 6: DOE seeks comment on core deactivation technology. DOE requests input on any considerations necessary for analyzing core deactivation systems composed of different component transformers. DOE also seeks comment on the types of applications that might benefit from using the technology, and any other considerations related to the incorporation of the technology into the test procedure. Issue 3: DOE seeks comment on its proposal to designate a 

### weighted - average loss calculation using various loadings to capture the energy savings potential of technologies that do not follow the loading vs. losses relationship evident in traditional transformer designs. DOE welcomes comment on 

### the appropriate weightings to use for the different load factors.41 | Building Technologies Program eere.energy.gov 

# Screening Analysis

Impacts on health or safety

Adverse impacts on equipment utility or availability to

consumers 

### Practicability to manufacture, install, and service

Technological feasibility 

## Purpose • Screen out technology options that DOE will not consider in the engineering analysis for distribution transformers. 

## Approach • DOE will evaluate each technology option based on the following criteria:42 | Building Technologies Program eere.energy.gov 

# Technology Options Screened Out of the Analysis Technology Option Excluded Screening Criteria Silver as a Conductor Material Practicability to manufacture, install, and service High - Temperature Superconductors Technological feasibility; Practicability to manufacture, install, and service Amorphous Core Material in Stacked Core Configuration Technological feasibility; Practicability to manufacture, install, and service Carbon Composite Materials for Heat Removal Technological feasibility High - Temperature Insulating Material Technological feasibility Solid - State (Power Electronics) Technology Technological feasibility; Practicability to manufacture, install, and service. 

### Nanotechnology Composites Technological feasibility43 | Building Technologies Program eere.energy.gov 

# Technology Options Screened Out of the Analysis – Request for Comment

Issue: DOE invites comment on the technology options 

### tentatively eliminated during the screening analysis. DOE also welcomes comment on any proprietary concerns relevant to the design options considered in the analysis. Issue 6.1: DOE knows of no current commercial efforts or prototype designs that employ nanotechnology composites in distribution transformers, but welcomes comment on such technology and its implications for the future of the industry.44 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Date

Screening Analysis Engineering

Analysis Energy Use and

End - Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Market & Technology Assessment

Preliminary

Manufacturer Impact Analysis Compliance Date45 | Building Technologies Program eere.energy.gov 

# Goals of the Engineering Analysis

Downstream Analyses

• Life- Cycle Cost and Payback Period Analysis



### • National Impact Analysis Manufacturer Selling Price – Efficiency Relationship Manufacturer Selling Price Efficiency Level 

### • To evaluate design options that improve efficiency.

• To characterize manufacturer selling price (MSP) versus efficiency for higher- efficiency distribution transformers.46 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Methodology

 Subdivide 10 equipment class groupings into 13 design lines based on similar principles of design. Identify rep units.  Identify design option combinations to characterize the spectrum of possible efficiencies. 

###  Identify materials prices, markups, labor requirements, and other cost components for each design option combination.  Use Optimized Program Service (OPS) software to model 

### optimized designs based on several hundred A and B values .  Develop candidate standard levels (CSLs) that span the range of efficiency from the baseline to the maximum technologically feasible.  Scale results to other equipment classes not analyzed. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs Model Optimized Designs Based on A’s and B’s Develop CSLs Scale to Equipment Classes Not Analyzed47 | Building Technologies Program eere.energy.gov 

# Engineering Design Lines and Representative Units

• Subdivide equipment classes into 13 engineering design lines based on similar principles of design and construction.

– Five liquid - immersed,

– Three LVDT, and

– Five MVDT.



### • Span a range of kVA ratings for which the 0.75 scaling rule would provide accurate results.

• Select one representative unit from each engineering design line. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed48 | Building Technologies Program eere.energy.gov 

# Liquid - Immersed Equipment Class to Design Line Mapping Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed49 | Building Technologies Program eere.energy.gov Equipment Class Design Line 

### Type of Distribution Transformer kVA

Range 

### Representative Unit
1 

### 1 Liquid - immersed,



### single - phase, rectangular tank 

### 10– 167 50 kVA, 65 ° C, single - phase, 60Hz, 

### 14400V primary, 240/120V secondary, rectangular tank 2 Liquid - immersed, single - phase, round tank 10– 167 25 kVA, 65 ° C, single - phase, 60Hz, 14400V primary, 240/120V secondary, round tank 3 Liquid - immersed, single - phase 250–833 500 kVA, 65 ° C, single - phase, 60Hz, 14400V primary, 277V secondary 

# Liquid - Immersed Design Lines and Representative Units

Issue 7: DOE welcomes comment on the representative units selected for the single - phase, liquid - immersed units 

### in design lines 1 through 3. Specifically, DOE seeks comment on its decision to use a 14400V primary voltage for design lines 1 through 3.50 | Building Technologies Program eere.energy.gov 

# Design Lines 5 and 13: Representative Units

Issues 8 & 9: DOE welcomes comment on the representative units selected for design lines 5 and 13. Specifically, DOE requests comment on the appropriate 

### primary voltage for analyzing these representative units. Equipment Class Design Line 

### Type of Distribution Transformer kVA

Range Representative Unit 2 5 Liquid - immersed,

three - phase 750–2500 1500 kVA, 65 ° C, three - phase, 60Hz, 24940GrdY/14400V primary, 

### 480Y/277V secondary 10 13 Dry-type, medium voltage, three - phase, 

### 96 - 150kV BIL 225–2500 2000 kVA, 150 ° C, three - phase, 60Hz, 12470V primary, 480Y/277V 

### secondary, 125kV BIL51 | Building Technologies Program eere.energy.gov 

# Design Lines and Representative Units

Issue 10: DOE welcomes comment on additional

representative units or design lines that should be considered in its analysis. DOE welcomes comment on 

### all aspects of its tentatively selected representative units and design lines. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed52 | Building Technologies Program eere.energy.gov 

# Identify Transformer Design Option Combinations

• Select design option combinations.

– Vary core configurations, core steels, and winding materials.



### – Capture most common designs and maximum efficiency. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s 

### Design Option Designs Considered

Core Configuration (Type) Wound core distributed gap;

Stacked butt - lap; Stacked full miter; Stacked cruciform miter. Core Configuration (Construction) 1 -Phase: Shell and Core type.

3-Phase: 3 - legged, 5 - legged and Symmetric Core. Core Steels Silicon steel: M12, M6, M5, M4, M3, M2.

Domain refined silicon steel: H - 0 DR (dry- type), ZDMH (liquid - immersed). Amorphous steel: SA1 (Dry- type and Liquid) Winding materials Copper;

Aluminum. Scale to Equipment Classes Not Analyzed53 | Building Technologies Program eere.energy.gov 

# Identify Transformer Design Option Combinations (Continued)

Design Option Core

Material Conductor

Primary Conductor

Secondary Core/Coil Design

Type 1 M12 Al Al 3 - leg stacked butt - lap 2 M12 Cu Al 3 - leg stacked butt - lap 3 M6 Al Al 3 - leg stacked butt - lap 4 M6 Al Al 3 - leg stacked full miter 5 M4 Cu Al 3 - leg stacked full miter 6 M3 Al Al 3 - leg stacked full miter 7* H - 0 DR Al Al 3 - leg stacked full miter 8 H - 0 DR Cu Cu 3 - leg stacked full miter 9* SA1 Al Al 5 - leg distributed gap core 10 SA1 Cu Cu 5 - leg distributed gap core * Note: Designs 7 and 9 are supplementary and not included in downstream analyses. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s 

### Example of Design Option Combinations Analyzed



### DL7: 75 kVA low -voltage dry- type, three - phase.

Scale to Equipment Classes Not Analyzed54 | Building Technologies Program eere.energy.gov 

# Identify Transformer Design Option Combinations (Continued)

Issue 12: DOE seeks comment on the design option combinations tentatively selected for analyzing each design line. DOE would like comments on any additional design option combinations that would yield efficiency 

### ratings greater than the domain - refined steels used in DOE‘s analysis. DOE considered ZDMH for liquid immersed designs and H - 0 DR for dry- type designs. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed55 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Markups and Labor Rate

• DOE determined materials prices and labor requirements through conversations with manufacturers and experts.
• DOE determined markups and labor rates from census data, SEC filings, and manufacturer interviews. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s 

### Markup / Cost Input Markup Notes

Scrap and handling 2.5 % Standard scrap and handling; applied to materials 1.5 % Prefabricated amorphous cores 4.0 % Additional scrap on fully mitered cores Factory overhead 12.5 % Applied to materials Shipping $ 0.22 / pound Added prior to profit markup; Approximately 4–8% of MSP Fully- burdened hourly labor rate $ 51.52 Applied to total labor hours Non - production 25 % Applied to total cost for SG&A, R&D, warranty/risk provisions, and profit factor Scale to Equipment Classes Not Analyzed56 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Markups and Labor Rate

Issue 13: DOE used 2010 materials prices for its analysis, and conducted high - price and low- price sensitivities using 2008 and 

### 2006 materials prices, respectively. DOE requests comment on its tentative decision to consider the current (2010) materials prices as the reference case materials price rather than a five year average price. Choose Rep. Design Lines and Units

Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed Select Higher Efficiency Design Options Develop Cost Inputs 

### Issue 14: DOE welcomes comment on its tentative decision to

use the same factory overhead markup for designs using a prefabricated amorphous core as for designs for which the manufacturer produces the core. Issue 15: DOE welcomes comment on its tentative decision to include shipping costs in the engineering analysis as a component of the manufacturer‘s selling price. DOE seeks 

### comment on whether profit markups are applied to the shipping cost, and if shipping costs are typically 4 - 8% of total revenue for the sale of distribution transformers.57 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Markups and Labor Rate

Issue 16: DOE seeks comment on the additional costs considered for amorphous designs in DLs 10, 12, and 13. 

### Additionally, DOE seeks comment on whether these additional costs apply to liquid - immersed design lines that are 1500 kVA or greater. • For large (1500 kVA or greater) dry - type designs using an amorphous core, DOE accounted for additional labor and 

### hardware costs. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Scale to Equipment Classes Not Analyzed Model Optimized Designs Based on A’s and B’s 

### Cost Factor Additional Amount per Design Rationale 

### Labor 10 hours Extra handling required for large, fragile amorphous cores. Hardware $230 to $330 Additional bracing necessary in large designs to contain the coil and prevent short circuit problems.58 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Modeling Optimized Designs

• Optimized Program Service (OPS) software conducts 

### design runs.

• As an input to the OPS software, economic parameters (A and B values) are varied to simulate a range of 

### customer orders, creating a database of transformer designs.

• Approximately 2,500 unique designs for each of the 

### thirteen representative units within each of the thirteen design lines. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed59 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Modeling Optimized Designs

• OPS design software output includes:

– Construction and winding instructions for the core and coil (e.g., core dimensions, high - and low-voltage windings, tap locations, insulation, cooling ducts, and labor).

– Bill of materials and electrical analysis report.



### • Material, labor costs and markups are combined to determine the manufacturer‘s selling price (MSP).



### • Temperature - corrected efficiency determined from OPS software electrical analysis report. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed60 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Modeled Designs from DL1 Rep Unit from DL1: 50 kVA liquid - immersed, single- phase, pad - mounted61 | Building Technologies Program eere.energy.gov



### • DOE was unable to identify a company that could model symmetric core designs.

• DOE gathered information on symmetric cores through manufacturer interviews, published literature, and limited 

### designs provided by manufacturers.

– Using these data sources, DOE roughly estimated the cost efficiency relationship of symmetric core designs.


### • Adjusted traditional core designs to simulate a symmetric core design: 

# Engineering Analysis: Symmetric Core Designs Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s 

### Adjustment Amount Reduced core losses - 15.5% Reduced core weight - 17.5% Increased labor costs +55.0% Scale to Equipment Classes Not Analyzed62 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Symmetric Core Designs

Issue 5: DOE requests comment on the adjustments used to estimate symmetric core cost - efficiency relationships, and welcomes any performance data 

### generated from simulation or testing that demonstrate the performance of symmetric core designs. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed63 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Develop Candidate Standard Levels

• DOE identified candidate standard levels (CSLs) that span the range of distribution transformer efficiencies from the baseline to the maximum technologically feasible efficiency.

• Factors DOE considered in setting CSLs: Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s 

### Benchmark efficiency levels (e.g., NEMA Premium) 

### Equally spaced efficiency increments Harmonization across single - phase and the per- phase kVA equivalent three - phase design lines.

Scale to Equipment Classes Not Analyzed64 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: CSLs for DL1 (50 kVA, 1 - phase)65 | Building Technologies Program eere.energy.gov 

# Developing Trial Standard Levels for the NOPR

• If DOE issues a NOPR, it will select trial standard levels

(TSLs) based on groupings of CSLs, such as:

– Per- phase harmonization, minimum LCC, and maximum NPV.



### • These TSLs may consider any interaction between 

### equipment classes.

• DOE will select its proposed standard level in the NOPR from the list of TSLs developed. Issue 17: DOE invites comment on the criteria it should 

### use as the basis for selection of TSLs. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed66 | Building Technologies Program eere.energy.gov 

# Medium - Voltage Dry -Type Equipment Class to Design Line Mapping

Medium -Voltage Dry-Type, Single- Phase • Single - phase MVDT units have low unit shipments and MVA 

### capacity shipped. • Rather than directly analyzing these units, DOE scaled to these units by dividing the kVA rating of three - phase MVDT units by three. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s
Scale to Equipment Classes Not Analyzed 

### Three- Phase Rep Unit kVA Single- Phase Scaled Unit kVA 300 100 1500 500 2000 667

Scales To...67 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Scaling Results

• DOE scaled the total losses (TL) from a representative unit to other unanalyzed kVA ratings (S) within a design line 

### using the 0.75 Scaling Rule:

TL 1 

### = TL 0 

### x (S 1 

### / S0



### ) 0.75



### • Costs of construction and losses can be scaled when design parameters are held constant, including:

– frequency, magnetic flux density, current density and insulation level. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Model Optimized Designs Based on A’s and B’s 

### Design Line 7 (LVDT, 3 - phase, 15 – 150 kVA): 75 kVA Representative Unit 15 

### kVA 30



### kVA 45



### kVA 75



### kVA 112.5



### kVA 150



### kVA Scale Results Scale to Equipment Classes Not Analyzed68 | Building Technologies Program eere.energy.gov 

# Engineering Analysis: Scaling Results

Issue 11: DOE welcomes comment on the 0.75 scaling rule and whether an improved scaling methodology 

### exists. DOE also welcomes comment on the extent of the impact that the previous scaled standard levels have had on the low kVA units for medium -voltage dry- type or for any other market segments. Choose Rep. Design Lines and Units Select Higher Efficiency Design Options Develop Cost Inputs
Develop CSLs Scale to Equipment Classes Not Analyzed Model Optimized Designs Based on A’s and B’s 

### • Some manufacturers indicated that the scaled results from

the 2007 rulemaking made it difficult to manufacture compliant transformers for certain kVA ranges.69 | Building Technologies Program eere.energy.gov 

### Markup Analysis; Energy Use & End - Use Load National Impact Analysis 

# Public Meeting Agenda

1 Overview

4 2 

### 3 Market & Tech; Screening; Engineering

6 5 Test Procedure

Life- Cycle Cost and Payback Period Analysis 7 Preliminary MIA; NOPR Analyses70 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Date

Screening Analysis Engineering

Analysis Energy Use and

End - Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Market & Technology Assessment

Preliminary

Manufacturer Impact Analysis Compliance Date71 | Building Technologies Program eere.energy.gov 

## • Purpose

– Determine customer prices under a standards scenario based on manufacturer costs.

– Characterize equipment distribution channels and market segments.



### – Describe distribution transformers‘ direct costs, expenses, and profits. 

## • Inputs

– RS Means Electrical Cost Data from 2010 • Derived contractor materials markups for dry-type transformers • Derived installation labor and equipment markups for both liquid immersed and dry-type transformers



### – Average sales tax rates for each Census division and large state 

## • Output

– Baseline markups. 

# Markups to Determine Equipment Price72 | Building Technologies Program eere.energy.gov 

## • Liquid - immersed and dry-type transformers have different distribution channels. • The majority of liquid - immersed transformers are purchased by utilities directly from manufacturers 

### or from the manufacturers 

### ‘ representative or distributor.

• Dry-type transformers are purchased and installed primarily by electrical contractors. For dry- type transformers, markups are applied at all points in the distribution channel.
 Chapter 3 of the TSD contains a detailed discussion regarding the distribution channels for distribution transformers. 

# Distribution Channels

Manufacturer Manufacturers‘ Representative or Distributor Utility

Manufacturer Manufacturers‘ Representative or Distributor Electrical Contractor C&I Customer73 | Building Technologies Program eere.energy.gov 

# Resulting Markup Multipliers 

# Liquid - Immersed Dry-Type Distributor 1.07 Distributor 1.15 Installation Materials 1.00 Contractor Materials 1.10 Installation Labor/Equip 1.43 Contractor Labor/Equip 1.43 Sales Tax Markup 1.069 Sales Tax Markup 1.069 Overall 

# 1.64 1.93 Issue 23: Distributor Markups . DOE estimated the distributor markups factors for liquid - immersed and dry- type transformers at 1.07 and 1.15, respectively. These factors are based on stakeholder comment from the previous 2007distribution transformers final rule. DOE welcomes comments on these markup factors.74 | Building Technologies Program eere.energy.gov 

### • Purpose :

– Develop annual energy use parameters needed for the calculation of transformer operating costs • For transformers, “energy use” refers to energy losses

– No - load losses • Parameterized by loss rate NL • Occur whenever the transformer is energized • Annual watt - hours = 8760*NL

– Load losses • Parameterized by loss rate LL = load loss at 100% load • Vary with the square of the load on the transformer 

### • Load dependence is captured through the loss factor LSF • LSF is proportional to the average value of the squared transformer load • Annual watt - hours = 8760*LL*LSF • The LCC must account for the existing of time-varying electricity costs

– Operating Cost = ∑ t 

### transformer_loss (t) × electricity_cost (t)

– t is the time period index 

# Energy Use Determination75 | Building Technologies Program eere.energy.gov 

# Liquid - immersed Transformers: Approach

• The utility is part of a larger system (ISO, market region, or control area)

– Use the EMM regions defined by the National Energy Modeling System (NEMS)

– Within each region there is a single system load and hourly marginal production price 

### • Hourly data compiled from FERC Form 714 filings for 2008

– Hourly form 714 loads are aggregated to produce regional system load

– Regional hourly costs are derived from system ―lambda‖ or day - ahead market clearing price76 | Building Technologies Program eere.energy.gov 

### • The annual operating cost is equal to a sum over hours of the hourly losses multiplied by the hourly price

– Operating_cost = LL* ∑ hours [X (hour)] 2 × marginal_production_cost (hour) 

### • LL is defined as the loss at full load, so the equation uses the hourly scaled transformer load X

– X is equal to the hourly transformer load divided by the peak transformer load

– For this discussion, assume the peak load is equal to the transformer capacity 

### • Simplify the calculation by noting that:

– The hourly production price is correlated with the hourly system load

– The hourly transformer load is correlated with the hourly system load 

### • The loading analysis models these two correlations 

# Liquid - immersed Transformers: Approach77 | Building Technologies Program eere.energy.gov 

# Liquid - immersed Transformers: Price - Load Correlation

• Hourly production price is correlated with the hourly system load

– Scatter plot of the hourly price (vertical axis) and hourly load (horizontal axis)

– Bin the data according to ranges of the load (stripes)

– Within each bin, price = average value + random increment • Regional system load data define how many hours per year the load is in each bin78 | Building Technologies Program eere.energy.gov • The hourly transformer load is correlated with the hourly system load • Redefine this as a statistical problem

– The system load is equal to the sum of the loads on each transformer in the system

– What is the correlation between the aggregate load and any individual load?

– Express this as a joint probability distribution function JPDF( system_load, transformer_load )

– The joint distribution function is estimated using hourly load data from buildings

– Define a JPDF for residential buildings, and a JPDF for commercial/industrial buildings 

## Liquid - immersed Transformers: System Load – Transformer Load Correlation

1 3 5 7 9

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Individual Load Bin

Aggregate Load Bin 0.000 - 0.005 0.005 - 0.010 0.010 - 0.015 0.015 - 0.020

1 3 5 7 9

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Individual Load Bin

Aggregate Load Bin 0.000 - 0.005 0.005 - 0.010 0.010 - 0.015 0.015 - 0.020 0.020 - 0.025 Residential Buildings Commercial Buildings79 | Building Technologies Program eere.energy.gov • Transformer owners are billed for electricity use based on a tariff • The LCC uses a customer sample of ~5000 commercial and small - industrial buildings

– Taken from the CBECS 1992 and 1995 surveys

– These buildings are used because they have monthly building - level electricity consumption and demand data

– These data are used to define a monthly building load factor (LF), equal to the average hourly load divided by the peak hourly load • To value the transformer load losses, the LCC requires monthly values for:

– The loss factor (LSF), equal to the average squared transformer load divided by the peak transformer load

– The responsibility factor (RF), equal to the squared transformer load divided by the peak transformer load during the hour of the building peak • Use statistical models, derived from hourly building data, that estimate LSF and RF as a function of the load factor LF 

# Dry-Type Transformers: Approach80 | Building Technologies Program eere.energy.gov 

### • The loss factor estimate is based on the rule - of- thumb

LSF = k × LF + (1

- k) × LF

2 

### with 0 ≤ k ≤ 1 

### • This equation is always true for some value of k between zero and one • Use data to calculate a set of values ( LF, LSF, k ) and estimate a distribution for k 

# Dry-Type Transformers: Loss Factor Calculations81 | Building Technologies Program eere.energy.gov 

### • The monthly responsibility factor (RF) defines the contribution of transformer load losses to the building peak demand • Expect the RF to be correlated to some degree with the load factor LF

– Low load factors imply temporally-variable loads and less predictable RF

– High load factors imply flat loads and higher, more predictable RF 

### • Use hourly building data to calculate a set of values ( LF, RF ) and define a distribution function that provides the probability of RF given a value for LF 

# Dry-type Transformers: Responsibility Factor Calculations82 | Building Technologies Program eere.energy.gov 

# Customer Evaluation Rates

Issue 21: Hourly Transformer Load Data. DOE seeks 

### comment on the availability of metered hourly data for liquid - immersed utility- owned transformers, and for drytype transformers installed in commercial or industrial buildings. Issue: Dry-type Transformer Installation Practices. DOE seeks comment on whether dry - type transformer installations are associated with specific end - use loads such as lighting or HVAC.83 | Building Technologies Program eere.energy.gov 

### Markup Analysis; Energy Use & End - Use Load National Impact Analysis 

# Public Meeting Agenda

1 Overview

4 2 

### 3 Market & Tech; Screening; Engineering

6 5 Test Procedure

Life- Cycle Cost and Payback Period Analysis 7 Preliminary MIA; NOPR Analyses84 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Date

Screening Analysis Engineering

Analysis Energy Use and

End - Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Market & Technology Assessment

Preliminary

Manufacturer Impact Analysis Compliance Date85 | Building Technologies Program eere.energy.gov 

### • Purpose

– To develop the customer life - cycle cost (LCC) savings and payback period (PBP) for higher- efficiency equipment compared to the baseline equipment. 

### • Method

– Use Monte Carlo simulation to estimate the life - cycle costs for a population of transformers (10,000 trials), implemented in an Excel® spreadsheet using Crystal Ball

– For each transformer, the LCC is equal to the total installed cost plus the sum of operating costs discounted to the base year

– For each transformer in the simulation, there is some random variation in • The choice of design for the baseline and standard level; • The transformer loading parameters; • The transformer price - load correlation; and • The transformer lifetime.

– The effect of an amended standard is to eliminate some designs from the available set

– This approach results in a distribution of LCC results for each candidate standard level. 

# Purpose86 | Building Technologies Program eere.energy.gov 

# Transformer Design Selection

Example: Design Line 1, Candidate Standard Level 187 | Building Technologies Program eere.energy.gov 

# LCC and PBP Analysis

A & B Parameter Transformer Designs A&B Selection

Markups & Total Installed Cost LCC Transformer Loading Electricity Cost & Prices Electricity Growth & Price Trends Discount Rates Compliance Date, Lifetime Transformer Design Selection

Simulate Load & Price

Discount Rate Selection Annual Operating Costs Operating Costs over the Lifetime of the Transformer Net Present Value of Lifetime Operating Cost From: Engineering Analysis

From: Energy Use and Load Characterization Analysis88 | Building Technologies Program eere.energy.gov



## • Liquid - immersed transformers

– Owners are electric utilities

– Electricity prices are hourly marginal production costs plus avoided capacity costs

– Use transformer- system load correlation to estimate transformer loads 

## • Dry-type transformers

– Owners are commercial and industrial (C&I) buildings.

– Electricity prices are monthly marginal consumption and demand charges

– Use monthly loss factor and peak responsibility factor to estimate transformer loads 

# Differences in the LCC Calculations89 | Building Technologies Program eere.energy.gov 

### • Some transformer owners use an estimate of the Total Ownership Cost (TOC) to choose a transformer design 

### • Their preferences are expressed through A and B values • A is the NPV of no - load losses ($ per watt) • B is the NPV of load losses ($ per watt) • The percentage of owners who choose designs based on some valuation of the losses are called evaluators • Three evaluation rate scenarios are defined in the LCC model 

# Customer Choice Model (1) Evaluation Rates

Design Lines Evaluation Scenario

Non - evaluators Default All - evaluators Liquid - immersed 1 — 5 0% 75% 100% Low-voltage Dry-type 6 — 8 0% 10% 100% Medium - capacity Dry-type 9,11 0% 50% 100% High - capacity Dry-type 10,12,13 0% 80% 100%90 | Building Technologies Program eere.energy.gov 

### • The Department uses data to develop estimates of A and B values for transformer owners • The A and B data capture current market purchase decision criteria 

### • A = NPV of no - load losses • B = NPV of load losses 

# Customer Choice Model (2) A and B Values

• Liquid - immersed • Data from previous analysis, supplemented by recent utility purchase bids • Data cluster around two values of the ratio B:A 

### • Dry- type • Derive A and B values from marginal electricity prices for commercial and industrial customers (ref. IEEE PC57.12.33/D8 Draft Guide for Distribution Transformer Loss Evaluation) y = 0.23x + 0.00 R2 = 0.91 y = 0.45x + 0.02 R2 = 0.61

0 1 2 3 4 5

0 2 4 6 8 10 12 14 Load Losses (B) $/W ( 2010$)

No - load Losses (A) $/W (2010$) Line 1 Line 2 Linear (Line 1) Linear (Line 2) Distributions of B Parameters versus A Parameters for

Liquid - Immersed Transformers91 | Building Technologies Program eere.energy.gov 

# Issues for Public Comment

Issue 24: Evaluation of Energy Efficiency in the Base Case. DOE seeks comment on the evaluation rates used in the analysis, particularly for MVDT transformers. Issue 22: Installation Practices. DOE seeks comment on 

### how to estimate the number of transformers installed in a building based on building characteristics such as total floor space, number of floors, or building activity.92 | Building Technologies Program eere.energy.gov 

## • Total Installed Costs = Manufacturer Selling Price + Installation Cost • Manufacturer Selling Price = Manufacturing Costs x Markups

– Manufacturing cost vs. efficiency relationships developed in the Engineering Analysis

– Markups and Sales Taxes developed in the Markups to Determine Equipment Price analysis 

## • Installation costs represent the labor and materials necessary to install the appliance

– Installation costs scale with transformer weight 

# Markup and Installed Costs93 | Building Technologies Program eere.energy.gov 

### • Hourly Marginal Electricity Production Costs

– Hourly data are compiled from FERC Form 714 filings for 2008

– For regions with functioning markets, use the day- ahead market clearing price

– For regions without markets, use the ―system lambda‖ data filed with FERC 

### • Regions are defined using the NEMS Electricity Market Module supply regions

– Within each region, use an average load - weighted sum of hourly prices to obtain a regional price.

– The capacity component is derived from auctions for regions with function capacity markets or from NEMS for all other regions. 

### • Develop a model of price vs. load from the FERC data

– Data are binned according to the load value

– Within each bin, price = average + random increment 

# Electricity Prices (1) Liquid - Immersed94 | Building Technologies Program eere.energy.gov 

## • Transformer owners are billed for electricity based 

## on a tariff • Use a database of 90 utility tariffs • For each building in the customer sample:

– CBECS data provide baseline electricity consumption and demand

– Buildings are assigned to utilities based on location (census division)



### – The tariff is used to estimate the price paid for a marginal increase in electricity consumption, and the price for a marginal increase in electricity demand

– These prices are calculated for two seasons, summer and winter 

## • Reference: Tariff - based Analysis of Commercial Building Electricity Prices , LBNL - 55551 

# Electricity Prices (2) Dry-Type95 | Building Technologies Program eere.energy.gov 

### • Energy price projections to 2035 based on EIA/AEO 2010 Reference Case • AEO High Growth and Low Growth (AEO2010) cases run as a sensitivity • Electricity price forecasts to 2075 are developed from the average rate of change over the period 2020 - 2035 

# Electricity Price Forecasts

80% 85% 90% 95% 100% 105% 110% 115% 120%

2005 2010 2015 2020 2025 2030 2035 Real Price Relative to 2007



### Year

Reference Case High Growth Low Growth96 | Building Technologies Program eere.energy.gov 

### • Based on the cost of funds used to purchase equipment:

– Most companies use both debt and equity capital to fund investments; the cost of capital is the weighted average of the cost of equity and debt financing.

– DOE estimated the cost of equity financing using the Capital Asset Pricing Model (CAPM).

– Data obtained from the Damodaran Online website.

– Transformer purchasers are represented by a sample of approximately 4,500 companies drawn from the owner categories shown in the table. 

# Discount Rates

Ownership Category Mean Real Discount Rate % Number of Observations Industrial Companies 6.8 11,944 Commercial Companies 6.2 9815 Commercial Property Owners 5.5 27 Utilities, Investor- Owned 5.2 314 Utilities, Publicly Owned 3.9 7 Government Offices 3.1 2697 | Building Technologies Program eere.energy.gov 

### • Average transformer lifetime is 32 years

– Reference: ORNL - 6847 Determination Analysis of Energy Conservation Standards for Distribution Transformers 

### • Each transformer in the LCC simulation has a unique lifetime • Failure rates:

– 0.5% per year from the first year of installation, due to lightning and other random causes

– Additional 0.5% per year due to corrosion, starting in year 15 

### • The failure rates are used to create a survival function, 

### assuming a standard Weibull shape 

# Service Lifetime98 | Building Technologies Program eere.energy.gov 

# Survival and Retirement Functions

Mean Lifetime: 32 years99 | Building Technologies Program eere.energy.gov 

# Replacement and Maintenance Practices Issue 25: Replacement and Maintenance Practices . DOE 

### seeks comment on current transformer replacement and maintenance practices, and sources of data on replacement rates, maintenance, and repair costs .100 | Building Technologies Program eere.energy.gov 

## • Results are presented for three representative design lines:

– Design Line 1 : Represents a rectangular- tank, single- phase, liquid - immersed distribution transformers, ranging from 10 kVA to 167 kVA . The representative unit selected for design line 1 is a 

### 50 kVA pad - mounted transformer.

– Design Line 7: Represents three- phase, low -voltage dry-type distribution transformers, ranging from 15 kVA to 150 kVA . The representative unit selected for design line 7 is a 75 kVA 

### transformer.

– Design Line 12: Represents three- phase, medium -voltage dry- type distribution transformers, ranging from 750 kVA to 2500 kVA . The representative unit selected for this design line is a 

### 1500 kVA transformer. 

# Results101 | Building Technologies Program eere.energy.gov 

# Results (1) Average Total Installed Costs
75 3 3102 | Building Technologies Program eere.energy.gov 

# Results (2) Average LCC Savings

 In the charts above, the box represents 25 to 75% of the distribution of results and the whiskers represent 5 to 95% of results. - 2000 - 1000 0 1000 2000 3000 4000

CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 Average LCC Savings ($)

Efficiency Level

Design Line 1: Liquid - immersed, 50 kVA ,

1 Phase, 125 kVA BIL Average LCC Savings

median average

- 4000 - 3000 - 2000 - 1000 0 1000 2000 3000 4000

CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 CSL 7 Average LCC Savings ($)

Efficiency Level

Design Line 7: Dry-type, 75 kVA, 3 Phase,

10 kVA BIL Average LCC Savings

median average103 | Building Technologies Program eere.energy.gov 

# Results (3) Average LCC Savings

- 2000 - 1000 0 1000 2000 3000 4000

CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 Average LCC Savings ($)

Efficiency Level

Design Line 12: Dry-type, 1500 kVA, 3 Phase,

125 kVA BIL Average LCC Savings

median average 

###  In the chart above, the box represents 25 to 75% of the distribution of results and the whiskers represent 5 to 95% of results.104 | Building Technologies Program eere.energy.gov 

## • LCC spreadsheet runs using only symmetric core designs • Results shown for baseline efficiency and several CSL • Distribution of LCC savings is comparable to standard designs; energy savings are larger 

# Emerging Technologies (1) Symmetric Core

- 1000 - 500 0 500 1000 1500 2000 2500 3000 3500

CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 Average LCC Savings ($)

Efficiency Level Design Line7: Dry-type, 75 kVA, 3 phase, 10 kVA BIL: Average LCC Savings

median average

- 30000 - 20000 - 10000 0 10000 20000 30000 40000

CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 Average LCC Savings ($)

Efficiency Level Design Line 12: Dry-type, 1500 kVA, 3 phase, 125 kVA BIL: Average LCC Savings

median average105 | Building Technologies Program eere.energy.gov 

## • Installation: replace a standard unit of capacity K with three units of capacity K/3 • Controls are used to deactivate units when the load falls below certain thresholds

– Can result in a substantial decrease in no - load losses • Replacing a single unit with three smaller, identical units of similar design is not cost-effective

– This is due to the 0.75 scaling rule

– Higher relative loading on the smaller units can result in an increase in load - losses • Optimal configurations can be defined given information on the expected distribution of loads 

# Emerging Technologies (2) Core Deactivation106 | Building Technologies Program eere.energy.gov 

### Markup Analysis; Energy Use & End - Use Load National Impact Analysis 

# Public Meeting Agenda

1 Overview

4 2 

### 3 Market & Tech; Screening; Engineering

6 5 Test Procedure

Life- Cycle Cost and Payback Period Analysis 7 Preliminary MIA; NOPR Analyses107 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Date

Screening Analysis Engineering

Analysis Energy Use and

End - Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Market & Technology Assessment

Preliminary

Manufacturer Impact Analysis Compliance Date108 | Building Technologies Program eere.energy.gov 

### • Shipments Analysis



# – To estimate liquid - immersed and dry- type distribution transformer shipments over time.



# – To estimate the disaggregation of shipments into equipment classes, and how this changes over time. • National Impact Analysis



# – To estimate the National Energy Savings (NES) liquid - immersed and dry type distribution transformer efficiency standards at different levels. • National energy savings calculated in quads for analysis period from 2016 - 2045 (35 years)



# – To estimate the national economic impact on the nation (or the Net Present Value (NPV)) from distribution transformer efficiency standards 

### at different levels. • NPV calculated in billions of dollars for products shipped over the analysis period from 2016 - 2045 

# Purpose109 | Building Technologies Program eere.energy.gov 

# Shipments Model Inputs

Input Data Source/Description Historical Shipments All Distribution Transformers • HVOLT shipments data for 2001 and 2009 • BEA quantity index data 1977 - 2008 Market Share Data All Distribution Transformers • Market Share by transformer type (liquid vs.dry): Historical and Forecasted EIA Electricity Retail Sales data by sector type • Market Share by kVA (capacity) rating: 2001 and 2009 HVOLT data by kVA (capacity) rating Replacements Distribution Transformer Lifetime • From Life - Cycle Cost Analysis Base Case Forecasted Shipments Liquid - Immersed Transformers • Same growth rate as EIA forecast of Electricity Retail Sales to all sectors Dry-Type Transformers • Same growth rate as EIA Forecast of Electricity Retail Sales to commercial and industrial sectors New Capacity Shipments All Distribution Transformers • Deduced from forecasted base case shipments and replacements Standards Case Forecasted Shipments: Long- Term Purchase Elasticity Liquid - Immersed Transformers • Price sensitivity based on transformer capacity-to - peak ratio Dry-Type Transformers • Price sensitivity based on sales and price data for Commercial Unitary AirConditioners110 | Building Technologies Program eere.energy.gov 

## • Utilized historical and forecasted EIA Electricity Retail Sales data by sector type to estimate market share by transformer type (liquid vs. dry) • Utilized HVOLT market share data by kVA (capacity) rating for 2001 and 2009; forecasted kVA market shares set equal to 2009 values 

# Equipment Class Market Shares

Issue 26: Forecasted Market Shares of Liquid - Immersed and DryType Distribution Transformers. This model was based on the shipments data for the years 2001 and 2009, as well as forecasted electricity sales with the assumption that transformer capacity market shares follow the relative electricity consumption of the end users. For each of the he market shares for different kVA ratings and equipment classes, DOE assumed that 

### the relative market share within each transformer type. DOE seeks comment on its approach.111 | Building Technologies Program eere.energy.gov 

### • Utilized BEA‘s Quantity Index data in combination with the 2001 and 2009 HVOLT historical shipments data to estimate historical 

### shipments. • Constructed base case forecast by estimating that shipments are driven by long - term growth in electricity consumption (sales). 

# Base Case Shipments Forecast

- 20,000 40,000 60,000 80,000 100,000 120,000 140,000

1950 1970 1990 2010 2030 2050 Shipments (MVA)

Shipments Estimate, All Transformers Historical Shipments, All Transfomers Shipments Estimate, Liquid - Immersed Transformers Shipments Estimate, Dry -Type Transformers112 | Building Technologies Program eere.energy.gov 

### • Impacts to Standards Case shipments forecasts due to purchase price and operating cost changes 

### • Liquid - immersed Transformers

– Predicted variability in observed transformer capacity - to - peak ratio as a function of variability in transformer price • Capacity-to - peak ratio data from historical FERC Form 1 data (1994 - 2001)



### – Obtained a value of - 0.04 for price elasticity • Consumers purchase transformers with relatively high capacity-to - peak ratios, implying less sensitivity to purchase price 

### • For Dry-Type Transformers

– Historical purchase data not available

– Because transformers are primarily used in commercial and industrial applications, DOE used sales and price data for 

### commercial unitary air conditioners as a proxy to estimate price elasticity.

– Obtained a value of - 0.02 for price elasticity 

# Purchase Price and Operating Cost Impacts113 | Building Technologies Program eere.energy.gov 

## • Very small impact to standards case shipments forecast for all CSLs 

# Standards Case Shipments Results114 | Building Technologies Program eere.energy.gov 

## • The shipments model provides annual age distribution of 

## transformers for past, present, and future years • Accounting for replacements allows estimate of age distribution of installed transformers 

# Affected Stock115 | Building Technologies Program eere.energy.gov 

## Age Distribution of Liquid - Immersed Transformer Stock: Four Selected Years

0 10000 20000 30000 40000 50000 60000 70000 80000 90000

0 10 20 30 40 50 60 Capacity (MVA)

Transformer Vintage (years)

Affected Stock: 0%



### 2010

0 10000 20000 30000 40000 50000 60000 70000 80000 90000

0 10 20 30 40 50 60 Capacity (MVA)

Transformer Vintage (years)

Affected Stock: 8%

### 2018

0 10000 20000 30000 40000 50000 60000 70000 80000 90000

0 10 20 30 40 50 60 Capacity (MVA)

Transformer Vintage (years)

Affected Stock: 58%



### 2035

0 10000 20000 30000 40000 50000 60000 70000 80000 90000

0 10 20 30 40 50 60 Capacity (MVA)

Transformer Vintage (years)

Affected Stock: 84%



### 2045116 | Building Technologies Program eere.energy.gov • Total Customer Cost

– Average values for individual design lines (for a specific kVA) as a function of efficiency level taken from LCC analysis • Repair and Maintenance Costs

– No increase in repair and maintenance costs with efficiency • Annual Load and No- Load Losses

– Average values for individual design lines (for a specific kVA) as a function of efficiency level taken from LCC analysis • Customer Evaluation Rates

– Inputs from LCC analysis (total customer cost, load and no - load losses, peak responsibility factor, RMS loading) account for customer evaluation rates • Peak Responsibility factor and Initial Peak Loading

– Average values taken for individual design lines from LCC analysis • RMS Loading

– Average values taken for individual design lines from LCC analysis • Marginal Energy and Demand Prices

– Average prices taken from LCC analysis

– Future energy prices adjusted according to trend forecasted from the 2010 Annual Energy Outlook • Electricity Site-to- Source Conversion Factors

– Conversion factors based on heat rates from NEMS corresponding to 2010 Annual Energy Outlook

– Average Heat Rate (Btu/kWh) for Base Load, and Average Gas Heat Rate (Btu/kWh) for Peak Load • Discount Rate

– 7% and 3% real from OMB‘s Regulatory Analysis Guideline A - 4 • Present Year

– Future expenses are discounted to the year 2010 

# National Impacts Analysis Inputs117 | Building Technologies Program eere.energy.gov 

### • Site Energy Savings and Cost Impacts from 13 Design Lines scaled to account for 115 kVA Capacity Class Ratings



### – LCC Analysis addresses 13 Design Lines with a  ̳representative unit‘ selected for each Design Line based on highest sales volume



### – National Impact Analysis needs to address 115 different kVA ratings

– Need to convert site energy savings and cost impacts from  ̳representative unit‘ to values representing all 115 kVA ratings

– 0.75 Scaling Rule used to perform conversion 

# Site Energy Savings and Cost Impacts118 | Building Technologies Program eere.energy.gov 

### • Used distribution of A and B values to capture the variability seen in the market, i.e., not all transformer purchases have identical costs of losses. 

### • Some transformer purchasers place no value on those losses while others place significant value. Those that do are said to be Evaluators. • Distinct evaluation percentages applied to liquid - immersed and dry-type. • Average input values from LCC analysis (purchase cost, NLL, LL, PRF, RMS loading) incorporate the evaluation rates used in the LCC analysis; no further adjustments needed for National Impact Analysis. 

# Customer Evaluation Rates

Design Lines Evaluation Scenario

Non - evaluators Default All - evaluators Liquid - immersed 1 — 5 0% 75% 100% Low-voltage Dry-type 6 — 8 0% 10% 100% Medium - capacity Dry-type 9,11 0% 50% 100% High - capacity Dry-type 10,12,13 0% 80% 100%119 | Building Technologies Program eere.energy.gov 

# Customer Evaluation Rates Issue 27: Customer Evaluation Rate Forecasts. To 

### accurately estimate the share of consumers that would be affected by a standard at a particular efficiency level, DOE‘s LCC and PBP analyses considered the percentage of the consumers that evaluate their purchase in the base and standards cases. 

### DOE invites comment on whether the number of purchasers who evaluate, or the evaluation criteria they use, are likely to change in the future.120 | Building Technologies Program eere.energy.gov 

# Example Annual Savings and Cost Results121 | Building Technologies Program eere.energy.gov 

## • Summary of Cumulative National Energy Savings (2016– 2045) and Net Present Value (2016–2104) Impact 

# Summary of Cumulative National Energy Savings Impact122 | Building Technologies Program eere.energy.gov 

### Markup Analysis; Energy Use & End - Use Load National Impact Analysis 

# Public Meeting Agenda

1 Overview

4 2 

### 3 Market & Tech; Screening; Engineering

6 5 Test Procedure

Life- Cycle Cost and Payback Period Analysis 7 Preliminary MIA; NOPR Analyses123 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Date

Screening Analysis Engineering

Analysis Energy Use and

End - Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Market & Technology Assessment

Preliminary

Manufacturer Impact Analysis Compliance Date124 | Building Technologies Program eere.energy.gov 

# Manufacturer Impact Analysis Overview Purpose • To identify the impacts of amended energy conservation standards on manufacturers.

• Key output of MIA is the change in industry net present value (INPV) due to amended standards.

• The MIA consists of three phases:

Industry profile Develop

straw- man GRIM* Develop

interview guide Interviews

& industrywide / subgroup analyses Assess direct

employment, competition, cumulative burden Phase 2 Phase 3 Phase 1125 | Building Technologies Program eere.energy.gov 

# Manufacturer Impact Analysis Overview Phase 1 • DOE creates an industry profile to characterize the industry and identify 

### important issues that require consideration. 

### Phase 2 • DOE prepares an industry cash -flow model and an interview questionnaire to guide subsequent discussions. 

### Phase 3 • DOE interviews manufacturers and assesses the impacts of amended standards both quantitatively (using the Government Regulatory Impact Model) 

### and qualitatively (impacts on competition, manufacturing capacity, employment, and regulatory burden).

Industry profile Develop

straw- man GRIM* Develop

interview guide Interviews

& industrywide / subgroup analyses Assess direct

employment, competition, cumulative burden Phase 2 Phase 3 Phase 1126 | Building Technologies Program eere.energy.gov 

# Preliminary Manufacturer Impact Analysis – Key Issues

• Core Steel Availability

– Limited global supply for higher efficiency core steels.

– Only a few global suppliers of M2 steel, and only one supplier of amorphous ribbon.



### • Equipment Conversion Costs

– Certain technology options require large capital investments, retooling, and stranded assets.

– Switching from butt - lap to miter, investing in symmetric core technology, or increased amorphous core production



### • Intellectual Property

– Many symmetric core designs are patented.

– Core deactivation technology is patented.127 | Building Technologies Program eere.energy.gov 

# Preliminary Manufacturer Impact Analysis – Key Issues (Continued) Issue 18: DOE requests comment on its identification of key issues in its preliminary manufacturer impact analysis and requests data to assist evaluating the potential impact of amended standards on manufacturers. Issue 19: DOE welcomes comment on the supply of core steels used in its designs. In particular, DOE seeks comment 

### on the global supply of grain - oriented silicon steel, such as M3 and M2, and amorphous core steels compared to the projected consumption based on CSLs.128 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date129 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date130 | Building Technologies Program eere.energy.gov 

# Revised Preliminary Analysis

Analysis Action Engineering Analysis • Consider comments
• Revise using latest data Life- Cycle Cost and Payback Period Analyses 

### • Consider comments
• Revise using latest data
• Conduct LCC sub - group analysis 

### National Impacts Analysis • Consider comments


### • Revise using latest data131 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date132 | Building Technologies Program eere.energy.gov 

### • Purpose

– Evaluate impacts on any identifiable groups or customers who may be disproportionately affected by any amended national energy efficiency standard level.
• Method

– Analyze the LCC and payback periods (PBPs) for those customers that fall into any identifiable groups. LCC spreadsheet model allows for 

### different inputs to represent particular groups.
• Output

– Customer subgroup life - cycle costs and payback periods.



### – Identification of subgroups particularly affected by an amended standard. 

# Life - Cycle Cost Subgroup Analysis133 | Building Technologies Program eere.energy.gov 

## DOE will evaluate the LCC impacts on the subgroups identified in the 2007 distribution transformers final rule.
• 

## Municipal Utilities

– Use transformers that tend to serve more diverse, urban loads than transformers that serve more rural areas. The increased load diversity increases 

### the load factor and the transformer loading, thus increasing the potential savings from reduced load losses. 

## • Rural Electric Cooperatives

– Use transformers that tend to serve smaller loads than transformers that serve 

### urban areas. The lower loading decreases the potential savings from reduced load losses and, thus, the benefits from efficiency improvements. 

## • Vault Installed Transformers

– Distribution transformers at higher efficiency levels have larger volumes and 

### higher installation costs, due to required modifications to enlarge the vaults that house them. This can dramatically decrease the economic benefits from the highest standard levels. 

# Proposed Subgroups134 | Building Technologies Program eere.energy.gov 

## • DOE will be especially sensitive to increases in the 

## purchase price of the equipment due to amended standards, to avoid negative impacts on identifiable population groups that may not be able to afford significant increases in equipment price. 

# Purchase Price Impacts135 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date136 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date137 | Building Technologies Program eere.energy.gov 

## • Purpose

– To investigate the effects on electric utilities from reduced energy consumption and reduced peak load demand due to amended energy conservation standards. 

## • Method

– Uses national energy savings results.

– Uses the Energy Information Administration‘s National Energy Modeling System (NEMS) tailored for DOE‘s Building Technologies Program (NEMS - BT). 

## • Output

– Change in electricity sales and price by region.

– Change in the mix of electricity generation.



### – Change in new capacity construction. 

# Utility Impact Analysis138 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date139 | Building Technologies Program eere.energy.gov 

# Employment Impact Analysis

• Purpose



# – To report net jobs created or eliminated nationally as a consequence of amended energy conservation standards. • Method



# – Uses the ImSET (Impact of Sector Energy Technologies) model for the evaluation of indirect employment impacts.



# – Changes in equipment and energy expenditures are developed in the National Energy Savings Analysis.



# – Direct employment impacts are developed in the Manufacturer Impact Analysis. • Output



# – Change in commercial and energy sector employment as a consequence of amended energy conservation standards140 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis Compliance Date141 | Building Technologies Program eere.energy.gov 

### • Purpose

– Report environmental impacts resulting from amended energy 

### conservation standards, including changes in power plant emissions 

### • Method

– Energy savings results taken from the National Energy Savings Analysis.

– Energy Information Administration‘s National Energy Modeling System (NEMS - BT) provides power- plant emissions. 

### • Output

– Estimate of national emission reductions of CO2, NOx , and mercury. • Carbon dioxide (CO2) will be the primary emissions reported. • Mercury (Hg) emissions will also be reported. • Nitrogen Oxide ( NOx) emissions will be reported for the 22 states where emissions are not capped. 

### • Discuss national emissions reductions of Sulfur Dioxide (SO2); existing legislation cap SO2, so physical emission reductions will be zero or nearly zero. 

# Environmental Assessment142 | Building Technologies Program eere.energy.gov 

### • DOE intends to use the most current Social Cost of Carbon (SCC) values developed by interagency reviews.

– SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including but not limited to agricultural productivity loss, human health effects, property damage from rising sea level, and changes in the ecosystem. 

### • At present, the most recent interagency estimates of the potential global benefits resulting from reduced CO2 emissions 

### in 2010 are $4.90, $22.10, $36.30, and $67.10 per metric ton in 2009 dollars.

– For emission reductions that occur in later years, these values grow in real terms over time. 

### • DOE will also estimate the potential monetary benefit of reduced NOx emissions resulting from the considered standard levels. 

# Environmental Assessment Monetization of Emission Reductions143 | Building Technologies Program eere.energy.gov 

# Environmental Assessment Issue 20: Valuing Air- Borne Emission Reductions. DOE 

### acknowledges that there may be certain benefits resulting from the improved efficiency of Distribution Transformers that are not captured directly by the equipment ̳s users. These include both environmental and energy security- related externalities that are not reflected in energy prices, such as reduced emissions of greenhouse gases and reduced use of fossil fuels for electricity generation. DOE invites comments on the nature and magnitude of such benefits. DOE also invites comment on possible approaches to monetizing the emission reductions expected to result from energy conservation standards144 | Building Technologies Program eere.energy.gov 

# Steps in the Standards Rulemaking: NOPR
Framework Document Preliminary

Analysis NOPR Final Rule Compliance

Date

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life- Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life- Cycle Cost & Payback Period Analyses National

Impact Analysis Revise Preliminary Analysis
Engineering Analysis145 | Building Technologies Program eere.energy.gov 

## • Purpose

– To investigate the national impacts due of non - regulatory alternatives 

### compared with mandatory amended energy conservation standards.

– The non - regulatory alternatives that may be considered include: • No new regulatory action; early replacement; prescriptive standards; customer tax credits; manufacturer tax credits; customer rebates; 

### voluntary efficiency targets and bulk government procurement. 

## • Method

– NES spreadsheet model is modified to consider scenarios. These include: energy prices and escalation factors; implicit market discount 

### rates; customer purchase price, operating cost, and income elasticities ; and equipment stock data. 

## • Output

– National Energy Savings and Net Present Value of the non - regulatory 

### alternatives.

– Impact of non - regulatory alternatives on purchase price and use of energy- efficient equipment. 

# Regulatory Impact Analysis146 | Building Technologies Program eere.energy.gov 

### • In all correspondence, please refer to the Distribution Transformers rulemaking by:



### – Distribution Transformers Rulemaking,

– Docket Number EE –2010– BT–STD–0048 , and

– Regulatory Identification Number (RIN) 1904–AC04
• Email : DistributionTransformers - 2010 - STD - 0048@ee.doe.gov

• Comment period closes: April 18, 2011 

# How to Submit Written Comments

Postal : Hand Delivery/Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE - 2J 1000 Independence Avenue, SW Washington, DC 20585 - 0121 Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Suite 600 950 L‘Enfant Plaza, SW Washington, DC 20024 Tel: 202 - 586 - 2945