Energy Conservation Program: Energy Conservation Standards for Distribution Transformers, 28239-28259 [2019-12761]
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28239
Proposed Rules
Federal Register
Vol. 84, No. 117
Tuesday, June 18, 2019
This section of the FEDERAL REGISTER
contains notices to the public of the proposed
issuance of rules and regulations. The
purpose of these notices is to give interested
persons an opportunity to participate in the
rule making prior to the adoption of the final
rules.
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE–2019–BT–STD–0018]
Energy Conservation Program: Energy
Conservation Standards for
Distribution Transformers
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
AGENCY:
ACTION:
Request for information.
SUMMARY: The U.S. Department of
Energy (‘‘DOE’’) is initiating an effort to
determine whether to amend the current
energy conservation standards for
distribution transformers. Under the
Energy Policy and Conservation Act of
1975, as amended, DOE must review
these standards at least once every six
years and publish either a notice of
proposed rulemaking (‘‘NOPR’’) to
propose new standards for distribution
transformers or a notice of
determination that the existing
standards do not need to be amended.
This request for information (‘‘RFI’’)
solicits information from the public to
help DOE determine whether amended
standards for distribution transformers
would result in significant energy
savings and whether such standards
would be technologically feasible and
economically justified. DOE welcomes
written comments from the public on
any subject within the scope of this
document (including topics not raised
in this RFI).
Written comments and
information are requested and will be
accepted on or before August 2, 2019.
DATES:
Interested persons are
encouraged to submit comments using
the Federal eRulemaking Portal at
https://www.regulations.gov. Follow the
instructions for submitting comments.
Alternatively, interested persons may
submit comments, identified by docket
number EERE–2019–BT–STD–0018, by
any of the following methods:
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ADDRESSES:
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1. Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: DistributionTransformers
2019STD0018@ee.doe.gov. Include the
docket number EERE–2019–BT–STD–
0018 in the subject line of the message.
3. Postal Mail: Appliance and
Equipment Standards Program, U.S.
Department of Energy, Building
Technologies Office, Mailstop EE–5B,
1000 Independence Avenue SW,
Washington, DC 20585–0121.
Telephone: (202) 287–1445. If possible,
please submit all items on a compact
disc (‘‘CD’’), in which case it is not
necessary to include printed copies.
4. Hand Delivery/Courier: Appliance
and Equipment Standards Program, U.S.
Department of Energy, Building
Technologies Office, 950 L’Enfant Plaza
SW, 6th Floor, Washington, DC 20024.
Telephone: (202) 287–1445. If possible,
please submit all items on a CD, in
which case it is not necessary to include
printed copies.
No telefacsimilies (faxes) will be
accepted. For detailed instructions on
submitting comments and additional
information on this process, see section
III of this document.
Docket: The docket for this activity,
which includes Federal Register
notices, comments, and other
supporting documents/materials, is
available for review at https://
www.regulations.gov. All documents in
the docket are listed in the https://
www.regulations.gov index. However,
some documents listed in the index,
such as those containing information
that is exempt from public disclosure,
may not be publicly available.
The docket web page can be found at
https://www.regulations.gov/#docket
Detail;D=EERE-2019-BT-STD-0018. The
docket web page contains instructions
on how to access all documents,
including public comments, in the
docket. See section III for information
on how to submit comments through
https://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Jeremy Dommu, U.S. Department
of Energy, Office of Energy Efficiency
and Renewable Energy, Building
Technologies Office, EE–5B, 1000
Independence Avenue SW, Washington,
DC 20585–0121. Telephone: (202) 586–
9870. Email: ApplianceStandards
Questions@ee.doe.gov.
Ms. Sarah Butler, U.S. Department of
Energy, Office of the General Counsel,
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GC–33, 1000 Independence Avenue SW,
Washington, DC 20585–0121.
Telephone: (202) 586–1777. Email:
sarah.butler@hq.doe.gov.
For further information on how to
submit a comment or review other
public comments and the docket contact
the Appliance and Equipment
Standards Program staff at (202) 287–
1445 or by email: ApplianceStandards
Questions@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Authority and Background
B. Rulemaking Process
C. Summary of the Impacts of the
Amorphous Steel Market on the Current
Standards for Liquid-Immersed
Distribution Transformers
D. Summary of the Impacts of the Steel
Market on the Current Standards for
Low-Voltage Dry-Type Distribution
Transformers
II. Request for Information and Comments
A. Equipment Covered by This Process
B. Market and Technology Assessment
1. Equipment Classes
2. Technology Assessment
3. Electrical Steel Market Assessment
C. Screening Analysis
D. Engineering Analysis
1. General Methodology
2. Price Inputs to Analysis
3. Load Loss Scaling
E. Distribution Channels
1. Liquid-Immersed Distribution
Transformers
2. Dry-Type Distribution Transformers
F. Energy Use Analysis
1. Hourly Load Analysis
2. Monthly Load Analysis
G. Life-Cycle Cost and Payback Period
Analysis
1. Base-Case Efficiency Distributions
2. Installation Costs
3. Electricity Prices
4. Future Electricity Prices
H. Shipments
1. Equipment Lifetimes
2. Purchase Price Elasticity and
Refurbished Transformers
I. Manufacturer Impact Analysis
J. Other Energy Conservation Standards
Topics
1. Market Failures
2. Emerging Smart Technology Market
3. Other
III. Submission of Comments
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I. Introduction
A. Authority and Background
The Energy Policy and Conservation
Act of 1975, as amended (‘‘EPCA’’),1
among other things, authorizes DOE to
regulate the energy efficiency of a
number of consumer products and
certain industrial equipment. (42 U.S.C.
6291–6317) Title III, Part C 2 of EPCA,
added by Public Law 95–619, Title IV,
section 441(a), established the Energy
Conservation Program for Certain
Industrial Equipment, which sets forth a
variety of provisions designed to
improve energy efficiency. This
equipment includes distribution
transformers, the subject of this RFI.
Congress directed DOE to prescribe
energy conservation standards for such
equipment. (42 U.S.C. 6317(a)(2))
Congress also established energy
conservation standards for low-voltage
dry-type distribution transformers. (42
U.S.C. 6295(y))
The energy conservation program
under EPCA consists essentially of four
parts: (1) testing, (2) labeling, (3) Federal
energy conservation standards, and (4)
certification and enforcement
procedures. Relevant provisions of
EPCA include definitions (42 U.S.C.
6311), energy conservation standards
(42 U.S.C. 6313), test procedures (42
U.S.C. 6314), labeling provisions (42
U.S.C. 6315), and the authority to
require information and reports from
manufacturers (42 U.S.C. 6316). Federal
energy efficiency requirements for
covered equipment established under
EPCA generally supersede State laws
and regulations concerning energy
conservation testing, labeling, and
standards. (42 U.S.C. 6316(a) and (b); 42
U.S.C. 6297)
On October 12, 2007, DOE established
energy conservation standards for
liquid-immersed distribution
transformers and medium-voltage, drytype (MVDT) distribution transformers.
72 FR 58190. The Energy Policy Act of
2005 (Pub. L. 109–58, EPACT 2005)
amended EPCA to establish energy
conservation standards for low-voltage
dry-type (LVDT) distribution
transformers.3 4 (42 U.S.C. 6295(y)) On
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1 All
references to EPCA in this document refer
to the statute as amended through America’s Water
Infrastructure Act of 2018, Public Law 115–270
(October 23, 2018).
2 For editorial reasons, upon codification in the
U.S. Code, Part C was redesignated Part A–1.
3 EPACT 2005 established that the efficiency of a
low-voltage dry-type distribution transformer
manufactured on or after January 1, 2007 shall be
the Class I Efficiency Levels for distribution
transformers specified in Table 4–2 of the ‘‘Guide
for Determining Energy Efficiency for Distribution
Transformers’’ published by the National Electrical
Manufacturers Association (NEMA TP 1–2002).
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April 18, 2013, DOE amended the
energy conservation standards for
liquid-immersed, MVDT, and LVDT
distribution transformers.5 78 FR 23335
(‘‘April 2013 standards rule’’).
The amended energy conservation
standards in the April 2013 standards
rule were informed by a series of
negotiated rulemaking sessions. DOE
established subcommittees under DOE’s
Energy Efficiency and Renewable
Energy Advisory Committee (ERAC), in
accordance with the Federal Advisory
Committee Act and the Negotiated
Rulemaking Act, to negotiate proposed
standards for the energy efficiency of
MVDT and liquid-immersed
distribution transformers, and LVDT
distribution transformers, separately. 76
FR 45471 (July 29, 2011); 76 FR 50148
(August 12, 2011). The ERAC
subcommittees consisted of
representatives of parties with a defined
stake in the outcome of the energy
conservation standards. The ERAC
subcommittee held multiple meetings to
negotiate the energy conservation
standards, wherein DOE presented both
draft and revised engineering, life-cycle
cost and national impact analyses and
results, based on input from
subcommittee members on a number of
topics. The resulting April 2013
standards rule was informed by the
content of the negotiation sessions. The
negotiating committee reached an
outright consensus regarding energy
conservation standards for MVDT
distribution transformers but not for
liquid-immersed or LVDT distribution
transformers. 78 FR 23346–22347.
The current energy conservation
standards are located in 10 CFR
431.196. The currently applicable DOE
test procedures for distribution
transformers appear at 10 CFR part 431,
subpart K, appendix A.
EPCA also requires that, not later than
6 years after the issuance of any final
rule establishing or amending a
standard, DOE must evaluate the energy
conservation standards for each type of
covered equipment, including those at
issue here, and publish either a notice
of determination that the standards do
4 Although certain provisions pertaining to
distribution transformers, including test procedures
and standards for LVDT distribution transformers,
have been established in the part of EPCA generally
applicable to consumer products (See, 42 U.S.C.
6291(35), 6293(b)(10), 6295(y)), they are commercial
equipment. Accordingly, DOE has established the
regulatory requirements for distribution
transformers, including LVDT distribution
transformers, in 10 CFR part 431, Energy Efficiency
Program for Certain Commercial and Industrial
Equipment. See, 70 FR 60407 (October 18, 2005).
5 The Technical Support Document for the April
2013 standards rule is available at the following:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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not need to be amended based on the
criteria established under 42 U.S.C.
6295(n)(2), or a NOPR including new
proposed energy conservation standards
based on the criteria at 42 U.S.C.
6295(o). (42 U.S.C. 6316(a); 42 U.S.C.
6295(m)(1))
If DOE determines not to amend a
standard based on the statutory criteria,
not later than 3 years after the issuance
of a final determination not to amend
standards, DOE must publish either a
new determination that standards for
the product do not need to be amended,
or a NOPR including new proposed
energy conservation standards. (42
U.S.C. 6316(a); 42 U.S.C. 6295(m)(3)(B))
If DOE decides to amend the standard
based on the statutory criteria, DOE
must publish a final rule not later than
two years after energy conservation
standards are proposed. (42 U.S.C.
6316(a); 42 U.S.C. 6295(m)(3)(A))
DOE must publicize its analysis and
determination to not amend standards
or to propose standards and provide an
opportunity for written comment. (42
U.S.C. 6316(a); 42 U.S.C. 6295(m)(2)) In
making either determination, DOE must
evaluate whether more stringent
standards would (1) result in significant
conservation of energy and (2) be both
technologically feasible and
economically justified. (42 U.S.C.
6316(a); 42 U.S.C. 6295(m)(1)(A)).
DOE is publishing this RFI to collect
data and information to inform its
decision consistent with its obligations
under EPCA.
B. Rulemaking Process
DOE must follow specific statutory
criteria for prescribing new or amended
standards for covered equipment. EPCA
requires that any new or amended
energy conservation standard be
designed to achieve the maximum
improvement in energy or water
efficiency that is technologically
feasible and economically justified. (42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A))
To determine whether a standard is
economically justified, EPCA requires
that DOE determine whether the
benefits of the standard exceed its
burdens by considering, to the greatest
extent practicable, the following seven
factors:
(1) The economic impact of the
standard on the manufacturers and
consumers of the affected products;
(2) The savings in operating costs
throughout the estimated average life of
the product compared to any increases
in the initial cost, or maintenance
expenses;
(3) The total projected amount of
energy and water (if applicable) savings
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likely to result directly from the
standard;
(4) Any lessening of the utility or the
performance of the products likely to
result from the standard;
(5) The impact of any lessening of
competition, as determined in writing
by the Attorney General, that is likely to
result from the standard;
(6) The need for national energy and
water conservation; and
(7) Other factors the Secretary of
Energy (Secretary) considers relevant.
(42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(I)–() thrVII)).
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DOE fulfills these and other
applicable requirements by conducting
a series of analyses throughout the
rulemaking process. Table I.1 shows the
individual analyses that are performed
to satisfy each of the requirements
within EPCA.
TABLE I.1— EPCA REQUIREMENTS AND CORRESPONDING DOE ANALYSIS
EPCA requirement
Corresponding DOE analysis
Technological feasibility ............................................................................
Economic Justification:
1. Economic impact on manufacturers and consumers ...........................
2. Lifetime operating cost savings compared to increased cost for the
product.
3. Total projected energy savings ............................................................
4. Impact on utility or performance ..........................................................
5. Impact of any lessening of competition ...............................................
6. Need for national energy and water conservation ...............................
7. Other factors the Secretary considers relevant ...................................
As detailed throughout this RFI, DOE
is publishing this document seeking
input and data from interested parties to
aid in the development of the technical
analyses on which DOE will ultimately
rely to determine whether (and if so,
how) to amend the standards for
distribution transformers.
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C. Summary of the Impacts of the
Amorphous Steel Market on the Current
Standards for Liquid-Immersed
Distribution Transformers
In the April 2013 standards rule, DOE
set energy conservation standards for
liquid-immersed distribution
transformers, LVDT distribution
transformers, and MVDT distribution
transformers. 75 FR 23338. In its
analyses of liquid-immersed
distribution transformers, DOE
considered seven sets of energy
efficiency levels, referred to as trial
standard levels (‘‘TSL’’). The levels
represent increasingly stringent levels of
energy conservation standards,
numbered from TSL 1, the least
stringent, to TSL 7, the most stringent.
78 FR 23397. DOE adopted TSL 1
energy conservation levels for liquidimmersed distribution transformers.
DOE did not adopt energy efficiency
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• Market and Technology Assessment.
• Screening Analysis.
• Engineering Analysis.
•
•
•
•
•
Manufacturer Impact Analysis.
Life-Cycle Cost and Payback Period Analysis.
Life-Cycle Cost Subgroup Analysis.
Shipments Analysis.
Markups for Product Price Determination.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Energy and Water Use Determination.
Life-Cycle Cost and Payback Period Analysis.
Shipments Analysis.
National Impact Analysis.
Screening Analysis.
Engineering Analysis.
Manufacturer Impact Analysis.
Shipments Analysis.
National Impact Analysis.
Employment Impact Analysis.
Utility Impact Analysis.
Emissions Analysis.
Monetization of Emission Reductions Benefits.
Regulatory Impact Analysis.
levels more stringent than TSL 1 in part
because of risks associated with
limitations in the available supply of
amorphous steel. At more stringent
required standard levels DOE
determined it likely that the market
would transition entirely to the use of
amorphous steel. 78 FR 23415–23418.
DOE was concerned that if this were the
case, there might not have been a
sufficient supply of amorphous steel to
meet manufacturers’ needs. Id.
DOE determined that the burden of
the risk that manufacturers would not
be able to obtain the quantities of
amorphous steel required to meet the
higher efficiency requirement levels
outweighed the benefits of adopting
these efficiency levels. Id. This
determination contributed to DOE’s
decision that the higher efficiency
requirement levels were not
economically justified. Id. Additionally,
DOE acknowledged that although the
industry could manufacture liquidimmersed distribution transformers at
TSL 2 and TSL 3 from steels other than
amorphous steel, amorphous steel was
the cheapest design option for at least
some of the transformer designs that
were analyzed at these levels. 78 FR
23417–23418. In the analysis that led up
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to the April 2013 standards rule, DOE
identified only one supplier that
produced amorphous steel in any
significant volume. DOE expressed
concern that this one supplier, together
with others that might enter the market,
would not be able to increase
production of amorphous steel rapidly
enough to supply the amounts that
would be needed by transformer
manufactures before the compliance
date of January 1, 2016, if any energy
efficiency levels higher than TSL 1 were
adopted. 78 FR 23414–23421
D. Summary of the Impacts of the Steel
Market on the Current Standards for
Low-Voltage Dry-Type Distribution
Transformers
In its analyses of low-voltage dry-type
distribution transformers for the April
2013 standards rule, DOE considered six
sets of trial standard levels with
increasingly stringent levels of energy
conservation standards and adopted
TSL 2 energy conservation levels. 78 FR
23337. DOE did not adopt energy
efficiency levels more stringent than
TSL 2 for low-voltage dry-type
distribution transformers in part
because of risks associated with
limitations in the available supply and
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quality of M4, M3, and amorphous
steels.6 78 FR 23421. If DOE required
more stringent levels of energy
conservation in low-voltage dry-type
distribution transformers, manufacturers
of the transformers might have had to
rely on M4, M3, or amorphous steels to
meet those conservation standards. Id.
DOE was concerned that if the next
most stringent energy conservation
levels were adopted (TSL 3), then a
significant number of small
manufacturers would be unable to
acquire the M4, M3 or higher quality
steels in sufficient supply and quality to
be able to compete. Id. DOE indicated
that this risk to small manufacturers
outweighed the benefits of adopting TSL
3 efficiency levels. Id. Additionally,
DOE was concerned that small
manufacturers might not be able to
procure sufficient amounts of
amorphous steel at competitive prices, if
at all, if energy conservation levels TSL
4, TSL 5, or TSL 6 were adopted. Id.
DOE indicated that the benefits of
energy conservation levels TSL 4
through TSL 6 would be outweighed in
part by this potential burden on
manufacturers. These determinations
contributed to DOE’s decision that
efficiency requirement levels higher
than TSL 2 were not economically
justified. 78 FR 23419–23421.
II. Request for Information and
Comments
In the following sections, DOE has
identified a variety of issues on which
it seeks input to aid in the development
of the technical and economic analyses
regarding whether amended standards
for distribution transformers may be
warranted. Additionally, DOE welcomes
comments on other issues relevant to
the conduct of this rulemaking that may
not specifically be identified in this
document. In particular, DOE notes that
under Executive Order 13771,
‘‘Reducing Regulation and Controlling
Regulatory Costs,’’ Executive Branch
agencies such as DOE are directed to
manage the costs associated with the
imposition of expenditures required to
comply with Federal regulations. See 82
FR 9339 (Feb. 3, 2017). Consistent with
that Executive Order, DOE encourages
the public to provide input on measures
DOE could take to lower the cost of its
energy conservation standards
rulemakings, recordkeeping and
reporting requirements, and compliance
and certification requirements
6 These steels are among the most common grades
used in manufacture of distribution transformers.
M3 and M4 are examples of ‘‘conventional’’ grainoriented electrical steel, whereas amorphous is the
lowest-loss grade and a practical necessity to reach
the very highest efficiency levels.
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applicable to distribution transformers
while remaining consistent with the
requirements of EPCA.
A. Equipment Covered by This Process
This RFI covers equipment that meets
the definitions of distribution
transformers, as codified at 10 CFR
431.192. The definitions for distribution
transformers were most recently
amended in an energy conservation
standards final rule. 78 FR 23433. The
current definition for a distribution
transformer codified in 10 CFR 431.192
is the following:
Distribution transformer means a
transformer that—
(1) Has an input voltage of 34.5 kV or
less;
(2) Has an output voltage of 600 V or
less;
(3) Is rated for operation at a
frequency of 60 Hz; and
(4) Has a capacity of 10 kVA to 2500
kVA for liquid-immersed units and 15
kVA to 2500 kVA for dry-type units; but
(5) The term ‘‘distribution
transformer’’ does not include a
transformer that is an—
(i) Autotransformer; (ii) Drive
(isolation) transformer; (iii) Grounding
transformer; (iv) Machine-tool (control)
transformer; (v) Nonventilated
transformer; (vi) Rectifier transformer;
(vii) Regulating transformer; (viii)
Sealed transformer; (ix) Specialimpedance transformer; (x) Testing
transformer; (xi) Transformer with tap
range of 20 percent or more; (xii)
Uninterruptible power supply
transformer; or (xiii) Welding
transformer.
DOE notes that the excluded
equipment listed above is specifically
excluded from energy conservation
standards under EPCA at 42 U.S.C.
6291(35)(B)(ii)). Definitions for these
terms are at 10 CFR 431.192 as follows:
Autotransformer means a transformer
that:
(1) Has one physical winding that
consists of a series winding part and a
common winding part;
(2) Has no isolation between its
primary and secondary circuits; and
(3) During step-down operation, has a
primary voltage that is equal to the total
of the series and common winding
voltages, and a secondary voltage that is
equal to the common winding voltage.
Drive (isolation) transformer means a
transformer that:
(1) Isolates an electric motor from the
line;
(2) Accommodates the added loads of
drive-created harmonics; and
(3) Is designed to withstand the
additional mechanical stresses resulting
from an alternating current adjustable
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frequency motor drive or a direct
current motor drive.
Grounding transformer means a threephase transformer intended primarily to
provide a neutral point for systemgrounding purposes, either by means of:
(1) A grounded wye primary winding
and a delta secondary winding; or
(2) A transformer with its primary
winding in a zig-zag winding
arrangement, and with no secondary
winding.
Liquid-immersed distribution
transformer means a distribution
transformer in which the core and coil
assembly is immersed in an insulating
liquid.
Machine-tool (control) transformer
means a transformer that is equipped
with a fuse or other over-current
protection device, and is generally used
for the operation of a solenoid,
contactor, relay, portable tool, or
localized lighting
Medium-voltage dry-type 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 34.5 kV.
Mining distribution transformer
means a medium-voltage dry-type
distribution transformer that is built
only for installation in an underground
mine or surface mine, inside equipment
for use in an underground mine or
surface mine, on-board equipment for
use in an underground mine or surface
mine, or for equipment used for digging,
drilling, or tunneling underground or
above ground, and that has a nameplate
which identifies the transformer as
being for this use only.
Nonventilated transformer means a
transformer constructed so as to prevent
external air circulation through the coils
of the transformer while operating at
zero gauge pressure.
Rectifier transformer means a
transformer that operates at the
fundamental frequency of an
alternating-current system and that is
designed to have one or more output
windings connected to a rectifier.
Regulating transformer means a
transformer that varies the voltage, the
phase angle, or both voltage and phase
angle, of an output circuit and
compensates for fluctuation of load and
input voltage, phase angle or both
voltage and phase angle.
Sealed transformer means a
transformer designed to remain
hermetically sealed under specified
conditions of temperature and pressure.
Special-impedance transformer
means any transformer built to operate
at an impedance outside of the normal
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impedance range for that transformer’s
kVA rating. The normal impedance
range for each kVA rating for liquidimmersed and dry-type transformers is
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shown in Table II.1 and Table II.2 of this
document, respectively.
TABLE II.1—NORMAL IMPEDANCE RANGES FOR LIQUID-IMMERSED DISTRIBUTION TRANSFORMERS
Single-phase transformers
Three-phase transformers
kVA
Impedance
(%)
10 .................................................................................................................................................
15 .................................................................................................................................................
25 .................................................................................................................................................
37.5 ..............................................................................................................................................
50 .................................................................................................................................................
75 .................................................................................................................................................
100 ...............................................................................................................................................
167 ...............................................................................................................................................
250 ...............................................................................................................................................
333 ...............................................................................................................................................
500 ...............................................................................................................................................
667 ...............................................................................................................................................
833 ...............................................................................................................................................
1.0–4.5
1.0–4.5
1.0–4.5
1.0–4.5
1.5–4.5
1.5–4.5
1.5–4.5
1.5–4.5
1.5–6.0
1.5–6.0
1.5–7.0
5.0–7.5
5.0–7.5
........................
kVA
15
30
45
75
112.5
150
225
300
500
750
1,000
1,500
2,000
2,500
Impedance
(%)
1.0–4.5
1.0–4.5
1.0–4.5
1.0–5.0
1.2–6.0
1.2–6.0
1.2–6.0
1.2–6.0
1.5–7.0
5.0–7.5
5.0–7.5
5.0–7.5
5.0–7.5
5.0–7.5
TABLE II.2—NORMAL IMPEDANCE RANGES FOR DRY-TYPE DISTRIBUTION TRANSFORMERS
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Single-phase transformers
Three-phase transformers
kVA
Impedance
(%)
15 .................................................................................................................................................
25 .................................................................................................................................................
37.5 ..............................................................................................................................................
50 .................................................................................................................................................
75 .................................................................................................................................................
100 ...............................................................................................................................................
167 ...............................................................................................................................................
250 ...............................................................................................................................................
333 ...............................................................................................................................................
500 ...............................................................................................................................................
667 ...............................................................................................................................................
833 ...............................................................................................................................................
1.5–6.0
1.5–6.0
1.5–6.0
1.5–6.0
2.0–7.0
2.0–7.0
2.5–8.0
3.5–8.0
3.5–8.0
3.5–8.0
5.0–8.0
5.0–8.0
........................
........................
Testing transformer means a
transformer used in a circuit to produce
a specific voltage or current for the
purpose of testing electrical equipment.
Transformer means a device
consisting of 2 or more coils of insulated
wire that transfers alternating current by
electromagnetic induction from 1 coil to
another to change the original voltage or
current value.
Transformer with tap range of 20
percent or more means a transformer
with multiple voltage taps, the highest
of which equals at least 20 percent more
than the lowest, computed based on the
sum of the deviations of the voltages of
these taps from the transformer’s
nominal voltage.
Uninterruptible power supply
transformer means a transformer that is
used within an uninterruptible power
system, which in turn supplies power to
loads that are sensitive to power failure,
power sags, over voltage, switching
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transients, line noise, and other power
quality factors.
Welding transformer means a
transformer designed for use in arc
welding equipment or resistance
welding equipment.
Issue A.1: DOE requests comment on
whether the definitions for distribution
transformers require any revisions—and
if so, how those definitions should be
revised. In particular, DOE requests
feedback regarding how closely the kVA
and voltage limits mirror those of
equipment generally considered to serve
in a power distribution capacity. DOE
also requests feedback on whether the
sub-category definitions currently in
place are appropriate or whether further
modifications are needed. If these subcategory definitions need modifying,
DOE seeks specific input on how to
define these terms.
Issue A.2: DOE requests comment on
whether additional equipment
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kVA
15
30
45
75
112.5
150
225
300
500
750
1,000
1,500
2,000
2,500
Impedance
(%)
1.5–6.0
1.5–6.0
1.5–6.0
1.5–6.0
1.5–6.0
1.5–6.0
3.0–7.0
3.0–7.0
4.5–8.0
5.0–8.0
5.0–8.0
5.0–8.0
5.0–8.0
5.0–8.0
definitions are necessary to close any
potential gaps in coverage between
equipment types. DOE also seeks input
on whether such products currently
exist in the market or whether they are
being planned for introduction. DOE
also requests comment on opportunities
to combine equipment classes that
could reduce regulatory burden.
B. Market and Technology Assessment
The market and technology
assessment that DOE routinely conducts
when analyzing the impacts of a
potential new or amended energy
conservation standard provides
information about the distribution
transformers industry that will be used
in DOE’s analysis throughout the
rulemaking process. DOE uses
qualitative and quantitative information
to characterize the structure of the
industry and market. DOE identifies
manufacturers, estimates market shares
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and trends, addresses regulatory and
non-regulatory initiatives intended to
improve energy efficiency or reduce
energy consumption, and explores the
potential for efficiency improvements in
the design and manufacturing of
distribution transformers. DOE also
reviews product literature, industry
publications, and company websites.
Additionally, DOE considers conducting
interviews with manufacturers to
improve its assessment of the market
and available technologies for
distribution transformers.
1. Equipment Classes
When evaluating and establishing
energy conservation standards, DOE
may divide covered equipment into
equipment classes by the type of energy
used, or by capacity or other
performance-related features that justify
a different standard. (42 U.S.C. 6316(a);
42 U.S.C. 6295(q)) In making a
determination whether capacity or
another performance-related feature
justifies a different standard, DOE must
consider such factors as the utility of the
feature to the consumer and other
factors DOE deems appropriate. (Id.)
There are currently eleven equipment
classes for distribution transformers,
one of which (mining transformers) is
not presently subject to energy
conservation standards. 10 CFR 431.196.
Ten of the eleven equipment classes are
determined according to the following
characteristics: (1) Type of transformer
insulation: Liquid-immersed or drytype, (2) Number of phases: Single or
three, (3) Voltage class: Low or medium
(for dry-type only), and (4) Basic
impulse insulation level (BIL) (for
MVDT only). The eleventh equipment
class is for mining transformers, which
is a reserved equipment class but is not
currently subject to energy conservation
standards. 10 CFR 431.196(d). Table II.3
of this document lists the current 11
equipment classes for distribution
transformers.
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TABLE II.3—EQUIPMENT CLASSES FOR DISTRIBUTION TRANSFORMERS
EC
Insulation
Voltage
Phase
BIL rating
kVA range
1 .......
2 .......
Liquid-immersed .........................
Liquid-immersed .........................
Medium .......................................
Medium .......................................
Single ..........................................
Three ...........................................
.....................
.....................
3 .......
4 .......
Dry-type ......................................
Dry-type ......................................
Low .............................................
Low .............................................
Single ..........................................
Three ...........................................
.....................
.....................
5 .......
6 .......
Dry-type ......................................
Dry-type ......................................
Medium .......................................
Medium .......................................
Single ..........................................
Three ...........................................
20–45kV ......
20–45kV ......
7 .......
8 .......
Dry-type ......................................
Dry-type ......................................
Medium .......................................
Medium .......................................
Single ..........................................
Three ...........................................
46–95kV ......
46–95kV ......
9 .......
10 .....
Dry-type ......................................
Dry-type ......................................
Medium .......................................
Medium .......................................
Single ..........................................
Three ...........................................
≥96kV ..........
≥96kV ..........
10–833 kVA.
15–2500
kVA.
15–333 kVA.
15–1000
kVA.
15–833 kVA.
15–2500
kVA.
15–833 kVA.
15–2500
kVA.
75–833 kVA.
225–2500
kVA.
11 .....
Mining Distribution Transformers
In the April 2013 standards rule, DOE
added a definition for mining
distribution transformers. 78 FR 23353–
23354; 10 CFR 431.192. In deciding not
to set standards for mining distribution
transformers, DOE explained that
mining transformers are subject to
several constraints that are not usually
concerns for transformers used in
general power distribution. Specifically
because space is critical in mines, an
underground mining transformer may
be at a considerable disadvantage in
meeting an efficiency standard; these
transformers must supply power at
several output voltages simultaneously;
and mining transformers in general
perform a role that may differ from
general power distribution in many
regards, including lifetime, loading, and
often the need to supply power at
several voltages simultaneously. 78 FR
23353. DOE stated that it may consider
establishing energy conservation
standards for mining distribution
transformers at a later date. 78 FR
23354. Specifically, DOE stated that it
may set standards if it believes that
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these transformers are being purchased
as a way to circumvent energy
conservation standards for distribution
transformers. Id.
Issue B.1: DOE requests information
on the sale and use of mining
transformers, including information
about the applications for which mining
transformers are currently being used,
manufacturers of mining transformers,
sales data identifying end-users, and
information about the selling price. DOE
requests comment on whether the
features of mining transformers
specified in the regulatory definition
limit its use to mining applications, or
whether they can be repurposed for
general, above-ground service. DOE also
requests data characterizing the relative
performance abilities of mining
transformers. In addition, if use of
mining transformers is observed in
applications other than underground,
DOE requests comments on whether
there are any technical aspects of
mining transformers that can be
identified to improve DOE’s definition
of mining transformers.
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In the April 2013 standards rule, DOE
also received several comments
regarding potential new equipment class
setting factors, in addition to those used
to establish the equipment classes
identified in Table II.3 of this document.
78 FR 23354–23359. Specifically, Table
II.4 provides the potential equipment
class setting factors (categories of
transformers) that were identified.
These potential class setting factors
could, if warranted, be used to further
subdivide the distribution transformers
currently subject to standards, as well as
any additional distribution transformers
potentially considered in a future
standards rulemaking. In the April 2013
standards rule, DOE determined that
these categories of transformers did not
warrant separate equipment classes, and
accordingly, these transformers are
subject to the existing equipment classes
shown in Table II.3 of this document.
DOE stated that it may consider
establishing separate equipment classes
for the same in the future.
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TABLE II.4—POTENTIAL CLASS SETTING FACTORS FOR DISTRIBUTION TRANSFORMERS
Transformer category
Description
Step-up transformers ......................
Transformers that increase voltage from primary to secondary (more secondary winding turns than primary
winding turns).
Transformers that are mounted above-ground on poles.
Transformers that are ground mounted, specifically in a locked steel cabinet mounted on a concrete pad.
Transformers that operate within a grid configuration and connect end loads to multiple distribution transformers simultaneously; often used for redundancy and in densely populated areas.
Transformers that have features unique to operation in a vault, which is a fully-enclosed chamber dedicated to housing the transformer and is not easily expandable.
Transformers that are able to maintain indefinite rated operation while submerged.
Transformers that are able to be reconfigured to accommodate different primary and secondary voltages,
in addition to those that can provide multiple voltages simultaneously.
Pole-mounted transformers ............
Pad-mounted transformers .............
Network transformers * ....................
Vault-based transformers * ..............
Submersible transformers * .............
Transformers with multi-voltage capacity.
* There may be considerable overlap between ‘‘network,’’ ‘‘vault-based,’’ and ‘‘submersible’’ transformers, i.e., transformers with one of the
three properties may often have another. However, they are separated here as they are not always linked and carry different features and
limitations.
Issue B.2: DOE requests comment on
whether equipment subject to present
and potential future energy conservation
standards should be classified based on
the factors presented in Table II.4 in any
potential future energy conservation
standards rulemaking. If so, DOE
requests information on (i) which new
equipment class(es) should be included,
and, (ii) how the performance-related
features of equipment in the class affect
both consumer utility and efficiency.
Additionally, DOE requests comment on
whether DOE should consider
additional equipment classes not
identified in the table, information on
the performance-related features that
provide unique consumer utility, and
data detailing the corresponding
impacts on energy use that would justify
separate equipment classes.
Lastly, DOE also received comments
from several stakeholders indicating BIL
affects efficiency in liquid-immersed
distribution transformers. 78 FR 23357–
23358. Specifically, some commenters
suggested setting separate energy
conservation standards based on BIL for
liquid-immersed distribution
transformers. 78 FR 23357. Commenters
stated that standards by BIL rating will
help differentiate transformers that
require more insulation and that are less
efficient. Id. Several other stakeholders
supported the concept of exploring how
BIL affects efficiency but felt that it was
not a significant enough issue to delay
publication of the rule. Id. Specifically,
commenters stated that the efficiency
levels under consideration do not
warrant separating by BIL and pointed
out that the efficiency impacts of varied
BIL were smaller in liquid-immersed
than in dry-type transformers. Id. While
DOE did not include equipment class by
BIL rating in the April 2013 standards
rule because DOE did not find a strong
technological need for such separation
at the efficiency levels under
consideration, DOE did state that it may
consider establishing equipment classes
by BIL rating when considering future
standards. 78 FR 23357–23358
Issue B.3: DOE requests comment on
whether separate equipment classes by
BIL rating should be considered for
liquid-immersed distribution
transformers. If so, please describe why
and provide information to characterize
the effect of BIL on performance.
2. Technology Assessment
In analyzing the feasibility of
potential new or amended energy
conservation standards, DOE uses
information about existing and past
technology options and prototype
designs to help identify technologies
that manufacturers could use to meet
and/or exceed a given set of energy
conservation standards under
consideration. In consultation with
interested parties, DOE intends to
develop a list of technologies to
consider in its analysis. That analysis
will likely include a number of the
technology options DOE previously
considered during its most recent
rulemaking for distribution
transformers.
In the April 2013 standards rule, DOE
identified several technology options
and designs considered under that
rulemaking.7 78 FR 23359. Increases in
transformer efficiency are based on
reduction of transformer losses. There
are two main types of losses in
transformers: No-load (core) losses and
load (winding) losses. Measures taken to
reduce one type of loss typically
increase the other type of loss. Some
examples of technology options to
improve efficiency include: (1) Highergrade electrical core steels, (2) different
conductor types and materials, and (3)
adjustments to core and coil
configurations. A summary of the
technology options from the April 2013
standards rule are presented in Table
II.5 and Table II.6 of this document.
TABLE II.5—PREVIOUSLY CONSIDERED TECHNOLOGY OPTIONS AND IMPACTS OF INCREASING TRANSFORMER EFFICIENCY
FOR THE APRIL 2013 STANDARDS RULE
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No-load
losses
To decrease no-load losses:
Use lower-loss core materials .....................................................................................................
Decrease flux density by:
Increasing core cross-sectional area (CSA) .........................................................................
Decreasing volts per turn .....................................................................................................
Decrease flux path length by decreasing conductor CSA ..........................................................
Use 120° symmetry in three-phase cores ** ...............................................................................
7 A more detailed discussion can be found in
section 3.8 of chapter 3, and chapter 4 of the April
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2013 standards rule Technical Support Document,
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Load losses
Cost impact
Lower ..........
No change *
Higher.
Lower
Lower
Lower
Lower
Higher ..........
Higher ..........
Higher ..........
No change ..
Higher.
Higher.
Lower.
TBD.
..........
..........
..........
..........
available from: https://www.regulations.gov/
document?D=EERE-2010-BT-STD-0048-0760.
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TABLE II.5—PREVIOUSLY CONSIDERED TECHNOLOGY OPTIONS AND IMPACTS OF INCREASING TRANSFORMER EFFICIENCY
FOR THE APRIL 2013 STANDARDS RULE—Continued
To decrease load losses:
Use lower-loss conductor material ..............................................................................................
Decrease current density by increasing conductor CSA .............................................................
Decrease current path length by:
Decreasing core CSA ...........................................................................................................
Increasing volts per turn .......................................................................................................
No-load
losses
Load losses
No change ..
Higher ..........
Lower ..........
Lower ..........
Higher.
Higher.
Higher ..........
Higher ..........
Lower ..........
Lower ..........
Lower.
Lower.
Cost impact
* Amorphous core materials would result in higher load losses because flux density drops, requiring a larger core volume.
** Sometimes referred to as a ‘‘hexa-transformer’’ design.
TABLE II.6—OTHER PREVIOUSLY CON- power output, and based on the known
SIDERED TECHNOLOGY OPTIONS IN efficiency of each combination of
THE APRIL 2013 STANDARDS RULE * transformers for any given loading, the
Silver as a Conductor Material
High-Temperature Superconductors
Amorphous Core Material in Stacked Core
Configuration
Carbon Composite Materials for Heat Removal
High-Temperature Insulating Material
Solid-State (Power Electronics) Technology
Nanotechnology Composites
* Note: These technology options were not
listed as such in the April 2013 standards rule
because they were removed in the screening
analysis.
Issue B.4: DOE requests comment on
the technologies listed in Table II.5 and
Table II.6 of this document regarding
their applicability to the current market,
costs, and how these technologies may
improve efficiency of distribution
transformers as measured according to
the DOE test procedure. DOE also seeks
information on how these technologies
and related costs may have changed
since they were considered in the April
2013 standards rule. Specifically, DOE
seeks information as to whether steel
grades and fabrication techniques have
been updated or improved since the
April 2013 standards rule.
In addition, DOE has also identified
several potential new technology
options that could improve efficiency of
distribution transformers. These new
technology options are presented in
Table II.7 of this document.
TABLE II.7—POTENTIAL NEW TECHNOLOGY OPTIONS FOR DISTRIBUTION
TRANSFORMERS
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Core Deactivation
Symmetric Core
Less-flammable insulating liquids
Core deactivation technology uses a
system of smaller transformers to
replace a single, larger transformer. For
example, three 25 kVA transformers
operating in parallel could replace a
single 75 kVA transformer. A control
unit constantly monitors the unit’s
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control unit operates the optimal
number of cores. In the April 2013
standards rule, DOE stated that although
core deactivation technology has some
potential to save energy over a realworld loading cycle, those savings
might not be represented in the current
DOE test procedure, and that each of the
constituent transformers must comply
with the applicable energy conservation
standard.8 78 FR 23360.
Symmetric core technology describes
a design strategy wherein each leg of the
transformer is connected to the other
two. It uses a continuously wound core
with 120-degree radial symmetry,
resulting in a triangularly shaped core
when viewed from above. Because of
zero-sequence fluxes 9 associated with
wye-wye connected transformers,
symmetric core designs may be best
suited to delta-delta or delta-wye
connections. In the April 2013
standards rule, DOE lacked the data
necessary to perform a thorough
engineering analysis of symmetric core
designs, and therefore did not consider
symmetric core technology for the
rulemaking.10 78 FR 23360–23362.
Less-flammable insulating liquid
technology is specific to liquidimmersed distribution transformers and
refers to filling these transformers with
an insulating fluid of higher flash
8 A more detailed discussion can be found on
page 3–28 of chapter 3 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
9 ‘‘Zero-sequence’’ is a term used to describe a
state in which flux among a transformer’s three
electrical phases is occurring simultaneously, rather
than at the usual staggered intervals. In this state,
damage or failure can be mitigated if both
connections (i.e., input and output) are of the delta
arrangement.
10 A more detailed discussion can be found on
page 3–29 of chapter 3 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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point 11 than that of traditional mineral
oil. This technology can benefit certain
applications in which a fire would be
especially costly. In the April 2013
standards rule, DOE considered whether
this technology might be
disproportionally affected by standards
set in the liquid-immersed equipment
class and concluded that was not likely
to be the case. Specifically, DOE
received some feedback suggesting that
less-flammable insulating liquids might
be capable of higher efficiencies than
mineral oil units because their higher
temperature tolerances may allow the
unit to be downsized and operated at
higher temperatures than those using
mineral oils.12 78 FR 23355.
Issue B.5: DOE requests comment on
the technologies listed in Table II.7 of
this document. Specifically, DOE seeks
information about technological
maturity, market adoption, costs, and
any related concerns (e.g., impacts on
consumer utility). DOE further requests
comment on its definition of core
deactivation technology as a system of
distribution transformers. DOE also
seeks comment on other technology
options that it should consider for
inclusion in its analysis.
Issue B.6: DOE seeks comment on
whether there have been sufficient
technological or market changes since
the most recent standards update that
may justify a new rulemaking to
consider more stringent standards.
Specifically, DOE seeks data and
information that could enable the
agency to determine whether DOE
should propose a ‘‘no new standard’’
determination because a more stringent
standard: 1. would not result in a
significant savings of energy; 2. is not
technologically feasible; 3. is not
11 The flash point is the lowest temperature at
which vapors above the fluid will ignite, given an
ignition source.
12 A more detailed discussion can be found on
page 3–24 of chapter 3, and page 5–22 of chapter
5 of the April 2013 standards rule Technical
Support Document, available from: https://
www.regulations.gov/document?D=EERE-2010-BTSTD-0048-0760.
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economically justified; or 4. any
combination of the foregoing.
3. Electrical Steel Market Assessment
a. Amorphous Steel—Producers
In its preliminary review of the
amorphous steel market, DOE identified
at least six companies with amorphous
steel mills either already in production
or at some stage of development. While
DOE is aware of only one producer of
amorphous ribbon in the United States;
three companies in China have each
recently increased their production
capacity; one corporation has built a
plant in South Korea and plans to enter
the amorphous steel market; and an
additional corporation produces at least
some amorphous steel. DOE has found
no indication that either of the two
domestic electrical steel production
companies have any plans to enter the
amorphous steel market.
Issue B.7: DOE seeks comments, data,
and information regarding current
producers of amorphous steel and any
barriers to entry by other producers or
factors that could lead existing
producers to exit the amorphous steel
market. Comments may include, but are
not limited to, identifying producers of
amorphous steel not already identified
in DOE’s preliminary review of the
amorphous steel market, and
anticipated future trends in producers
entering and exiting this market.
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b. Amorphous Steel—Production
Capacity
In its preliminary analysis of the steel
market, DOE identified the quantity of
amorphous steel produced by some of
the companies currently in production.
The global annual production capacity
of amorphous ribbon of the one
established producer is at least 100,000
tons of which 45,000 tons are located in
the United States. Additionally, the
three mills in China have recently
increased their collective annual
production capacity to 90,000 tons of
amorphous steel and had plans, as of
September 2016, to add an additional
40,000 to 50,000 tons in 2016.
Issue B.8: DOE seeks comments, data,
and information quantifying and
characterizing the current market
capacity for amorphous steel, and
potential changes in the production
capacity as compared to current
production capacity.
c. Amorphous Steel—Quality
In its preliminary analysis of the steel
market, DOE also identified
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improvements in the quality of
amorphous steel produced by some of
the steel makers. In particular, the
brittleness, stacking factor, and flux
density of the amorphous steel
produced in China have been improved
since the April 2013 standards rule was
issued. Additionally, the three
companies in China can all now
produce amorphous steel in the same
widths as available on the U.S. market.
Issue B.9: DOE seeks comments, data,
and information about historic trends in
the quality of amorphous steel, the
quality of the amorphous steel currently
in production as it pertains to use in
manufacturing energy-efficient
distribution transformers. Additionally,
DOE seeks comments, data, and
information about any planned changes
in the quality of amorphous steel and
potential future trends in the quality of
amorphous steel.
d. Non-Amorphous Steel—Market
Conditions
In its preliminary review of the core
steel market, DOE identified an increase
in the use by transformer manufacturers
of high permeability steels rather than
M3 steel, which has resulted, in part,
due to efficiency standards in the
United States, the European Union, and
India as well as China’s efforts to
improve the efficiency of its electricity
grid.
Issue B.10: DOE seeks comments,
data, and information about changes in
the market conditions for low-voltage,
dry-type distribution transformers that
could inform DOE’s decision to
reevaluate the current energy
conservation standards including any
changes in the availability and quality
of M4, M3, or other steels used in the
manufacturing of efficient low-voltage
dry-type distribution transformers.
C. Screening Analysis
The purpose of the screening analysis
is to evaluate the technologies that
improve equipment efficiency to
determine which technologies will be
eliminated from further consideration
and which will be passed to the
engineering analysis for further
consideration.
DOE determines whether to eliminate
certain technology options from further
consideration based on the following
criteria defined at 10 CFR part 430,
subpart C, appendix A, 4(a)(4) and 5(b)
as follows:
(1) Technological feasibility.
Technologies that are not incorporated
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28247
in commercial products or in working
prototypes will not be considered
further.
(2) Practicability to manufacture,
install, and service. If it is determined
that mass production of a technology in
commercial products and reliable
installation and servicing of the
technology could not be achieved on the
scale necessary to serve the relevant
market at the time of the compliance
date of the standard, then that
technology will not be considered
further.
(3) Impacts on equipment utility or
equipment availability. If a technology
is determined to have significant
adverse impact on the utility of the
equipment to significant subgroups of
consumers, or result in the
unavailability of any covered equipment
type with performance characteristics
(including reliability), features, sizes,
capacities, and volumes that are
substantially the same as equipment
generally available in the United States
at the time, it will not be considered
further.
(4) Adverse impacts on health or
safety. If it is determined that a
technology will have significant adverse
impacts on health or safety, it will not
be considered further.
Technology options identified in the
technology assessment are evaluated
against these criteria using DOE
analyses and inputs from interested
parties (e.g., manufacturers, trade
organizations, and energy efficiency
advocates). Technologies that pass
through the screening analysis are
referred to as ‘‘design options’’ in the
engineering analysis. Technology
options that fail to meet one or more of
the four criteria are eliminated from
consideration.
Additionally, DOE notes that the four
screening criteria do not directly
address the propriety status of
technology options. DOE only considers
potential efficiency levels achieved
through the use of proprietary designs
in the engineering analysis if they are
not part of a unique pathway to achieve
that efficiency level (i.e., if there are
other non-proprietary technologies
capable of achieving the same efficiency
level).
Table II.8 summarizes the technology
options that DOE screened out in the
April 2013 standards rule, and the
applicable screening criteria.
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TABLE II.8—PREVIOUSLY SCREENED OUT TECHNOLOGY OPTIONS FROM THE APRIL 2013 STANDARDS RULE 13
Technology option excluded
Eliminating screening criteria
Silver as a Conductor Material .................................................................
High-Temperature Superconductors ........................................................
Amorphous Core Material in Stacked Core Configuration .......................
Carbon Composite Materials for Heat Removal ......................................
High-Temperature Insulating Material ......................................................
Solid-State (Power Electronics) Technology ............................................
Nanotechnology Composites ....................................................................
Issue C.1: DOE requests feedback on
how the four screening criteria would
relate to the possible technology options
available for distribution transformers
listed in section II.A of this document,
and any other technologies not
identified in this document.
Issue C.2: DOE seeks information on
whether the technology options listed in
section II.B.2 of this document would
continue to be eliminated from further
consideration based on the four
screening criteria.
D. Engineering Analysis
The engineering analysis estimates
the cost-efficiency relationship of
equipment at different levels of
increased energy efficiency (‘‘efficiency
levels’’). This relationship serves as the
basis for the cost-benefit calculations for
consumers, manufacturers, and the
Nation. In determining the costefficiency relationship, DOE estimates
the increase in manufacturer production
cost (‘‘MPC’’) associated with increasing
the efficiency of equipment above the
baseline, up to the maximum
technologically feasible (‘‘max-tech’’)
efficiency level for each equipment
class.
DOE historically has used the
following three methodologies to
generate incremental manufacturing
Practicability to manufacture, install, and
Technological feasibility; Practicability to
ice.
Technological feasibility; Practicability to
ice.
Technological feasibility.
Technological feasibility.
Technological feasibility; Practicability to
ice.
Technological feasibility.
costs and establish efficiency levels
(‘‘ELs’’) for analysis: (1) The designoption approach, which provides the
incremental costs of adding to a baseline
model design options that will improve
its efficiency; (2) the efficiency-level
approach, which provides the relative
costs of achieving increases in energy
efficiency levels, without regard to the
particular design options used to
achieve such increases; and (3) the costassessment (or reverse engineering)
approach, which provides ‘‘bottom-up’’
manufacturing cost assessments for
achieving various levels of increased
efficiency, based on detailed cost data
for parts and material, labor, shipping/
packaging, and investment for models
that operate at particular efficiency
levels.
1. General Methodology
In the April 2013, standards rule, DOE
based its engineering analysis on a
design-option approach, in which
design software was used to assess the
cost-efficiency relationship between
various design option combinations.14
78 FR 23364. DOE analyzed eleven
equipment classes, as discussed in
section II.B.1. DOE then further
classified distribution transformers by
their kVA rating, within each equipment
class. These kVA ratings are essentially
service.
manufacture, install, and servmanufacture, install, and serv-
manufacture, install, and serv-
size categories, indicating the power
handling capacity of the transformers.
For the rulemaking, there was a total of
100 kVA ratings across all equipment
classes.
DOE recognized that it would be
impractical to conduct a detailed
engineering analysis on each kVA
rating, and therefore developed an
approach that simplified the analysis
while retaining reasonable levels of
accuracy. DOE found that many of the
units share similar designs and
construction methods and, on that basis,
DOE simplified the analysis by creating
engineering design lines (DLs), which
group kVA ratings based on similar
principles of design and construction.
The DLs subdivide the equipment
classes to improve the accuracy of the
engineering analysis. These DLs
differentiate the transformers by
insulation type (liquid immersed or drytype), number of phases (single or
three), and primary insulation levels for
medium-voltage dry-type distribution
transformers (three different BIL
levels).15 78 FR 23364.
After developing its DLs, DOE then
selected one representative unit from
each DL for study, greatly reducing the
number of units for direct analysis.
These representative units are listed in
Table II.9 of this document.
TABLE II.9—ENGINEERING DESIGN LINES AND REPRESENTATIVE UNITS
jbell on DSK3GLQ082PROD with PROPOSALS
EC *
DL
Type of distribution transformer
1 ........
1
1 ........
2
1 ........
2 ........
3
Liquid-immersed,
single-phase,
rectangular tank.
Liquid-immersed,
single-phase,
round tank.
Liquid-immersed, single-phase .....
250–833
4
Liquid-immersed, three-phase ......
15–500
13 A more detailed discussion can be found in
chapter 4 of the April 2013 standards rule
Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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10–167
10–167
Representative unit
50 kVA, 65 °C, single-phase, 60Hz, 14400V primary, 240/120V secondary, rectangular tank, 95kV BIL.
25 kVA, 65 °C, single-phase, 60Hz, 14400V primary, 120/240V secondary, round tank, 125 kV BIL.
500 kVA, 65 °C, single-phase, 60Hz, 14400V primary, 277V secondary, 150kV BIL.
150 kVA, 65 °C, three-phase, 60Hz, 12470Y/7200V primary, 208Y/
120V secondary, 95kV BIL.
14 A more detailed discussion can be found on
page 5–2 of chapter 5 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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15 A more detailed discussion of the structure of
the engineering analysis can be found on page 5–
1 of chapter 5 of the April 2013 standards rule
Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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TABLE II.9—ENGINEERING DESIGN LINES AND REPRESENTATIVE UNITS—Continued
EC *
DL
Type of distribution transformer
kVA range
2 ........
5
Liquid-immersed, three-phase ......
750–2500
3 ........
6
15–333
4 ........
7
Dry-type,
low-voltage,
singlephase.
Dry-type, low-voltage, three-phase
4 ........
8
Dry-type, low-voltage, three-phase
225–1000
6 ........
9
6 ........
10
8 ........
11
8 ........
12
10 ......
13A
10 ......
13B
Dry-type, medium-voltage,
phase, 20–45kV BIL.
Dry-type, medium-voltage,
phase, 20–45kV BIL.
Dry-type, medium-voltage,
phase, 46–95kV BIL.
Dry-type, medium-voltage,
phase, 46–95kV BIL.
Dry-type, medium-voltage,
phase, 96–150kV BIL.
Dry-type, medium-voltage,
phase, 96–150kV BIL.
15–150
three-
15–500
three-
750–2500
three-
15–500
three-
750–2500
three-
75–833
three-
225–2500
Representative unit
1500 kVA, 65 °C, three-phase, 60Hz, 24940GrdY/14400V primary,
480Y/277V secondary, 125 kV BIL.
25 kVA, 150 °C, single-phase, 60Hz, 480V primary, 120/240V secondary, 10kV BIL.
75 kVA, 150 °C, three-phase, 60Hz, 480V primary, 208Y/120V secondary, 10kV BIL.
300 kVA, 150 °C, three-phase, 60Hz, 480V Delta primary, 208Y/
120V secondary, 10kV BIL.
300 kVA, 150 °C, three-phase, 60Hz, 4160V Delta primary, 480Y/
277V secondary, 45kV BIL.
1500 kVA, 150 °C, three-phase, 60Hz, 4160V primary, 480Y/277V
secondary, 45kV BIL.
300 kVA, 150 °C, three-phase, 60Hz, 12470V primary, 480Y/277V
secondary, 95kV BIL.
1500 kVA, 150 °C, three-phase, 60Hz, 12470V primary, 480Y/277V
secondary, 95kV BIL.
300 kVA, 150 °C, three-phase, 60Hz, 24940V primary, 480Y/277V
secondary, 125kV BIL.
2000 kVA, 150 °C, three-phase, 60Hz, 24940V primary, 480Y/277V
secondary, 125kV BIL.
jbell on DSK3GLQ082PROD with PROPOSALS
* There is not a 1:1 correspondence of equipment classes and design lines.
Issue D.1: For each representative
unit, DOE generated hundreds of unique
designs by contracting with Optimized
Program Services, Inc. (OPS), a software
company specializing in transformer
design. The OPS software used three
primary inputs that it received from
DOE: (1) A design option combination,
which included core steel grade,
primary and secondary conductor
material, and core configuration; (2) a
loss valuation combination; and (3)
material prices. For each representative
unit, DOE examined anywhere from 8 to
16 design option combinations and for
each design option combination, the
OPS software generated 518 designs
based on unique loss valuation
combinations. These loss valuation
combinations are known in industry as
A and B evaluation combinations, and
represent a commercial consumer’s
present value of future losses in a
transformer core and winding,
respectively. For each design option
combination and A and B combination,
the OPS software generated an
optimized transformer design based on
the material prices that were also part of
the inputs. Consequently, DOE obtained
thousands of transformer designs for
each representative unit. The
performance of these designs ranged in
efficiency from a baseline level,
equivalent to the current distribution
transformer energy conservation
standards, to a theoretical max-tech
efficiency level. DOE requests comment
on whether a future rulemaking, if
initiated, should include a greater
breadth or depth of engineering design
simulations.
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After generating each design, DOE
used the outputs of the OPS software to
help create a manufacturer selling price
(MSP). The material cost corresponding
to the outputs of the OPS software,
along with labor estimates, were marked
up for scrap factors, factory overhead,
shipping, and non-production costs to
generate a MSP for each design. Thus,
DOE obtained a cost versus efficiency
relationship for each representative
unit. Finally, after DOE generated the
MSPs versus efficiency relationship for
each representative unit, it extrapolated
the results to the other, unanalyzed,
kVA ratings within that same
engineering design line.
Issue D.2: DOE requests comment on
whether its method of performing the
engineering analysis should be
maintained in any future rulemaking
analysis, if conducted.
Issue D.3: DOE requests comment on
whether there are additional methods to
establish the relationship between
transformer selling price and efficiency.
For example, DOE seeks comment on
whether bid responses for publicly
owned utilities would provide a
representative design and pricing data
to develop a more accurate costefficiency relationship and whether
such data exists in sufficient volume at
efficiency levels above the Federal
minimum.
2. Price Inputs to Analysis
As described at the beginning of this
section, the main outputs of the
engineering analysis are cost-efficiency
relationships that describe the estimated
increases in MPC associated with
higher-efficiency equipment for each
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analyzed equipment class. For
distribution transformers, one of the
inputs to the MPC is the materials costs.
The primary material costs in
distribution transformers come from
electrical steel used for the core and the
aluminum or copper conductor used for
the primary and secondary winding.
DOE attempted to account for the
frequent fluctuation in price of these
commodities by examining prices over
multiple years.
For the April 2013 standards rule,
DOE used its estimates of both 2010year and 2011-year prices as reference
cases for results. To construct materials
price estimates, DOE spoke with
manufacturers, suppliers, and industry
experts to determine the prices paid for
each raw material used in a distribution
transformer. DOE developed an average
materials price for the year based on the
price a medium-to-large manufacturer
would pay.16 78 FR 23367.
The prices of aluminum and copper
conductor, in particular, correlated
strongly to the price of the underlying
commodities, which are tracked in
various public indices (e.g. the LME). As
a result, extrapolation of 2010- and
2011-year prices using the index prices
of a future time period may yield
sufficiently accurate conductor prices
for that time period. Extrapolation of
past conductor prices may be more
accurate than direct use of the index
prices, as the latter do not include
16 A more detailed discussion can be found on
page 5–40 of chapter 5 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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transformer industry-specific costs such
as drawing into wire and shipping.
Issue D.4: DOE requests comment on
whether metals price indices, such as
those published by the London Metal
Exchange (LME) and CME Group (e.g.,
the COMEX), may be reliably used to
extrapolate 2010 and 2011 prices to the
present. DOE requests comment on
whether there are any other price
indices that should be considered. DOE
also requests comment on the impact of
tariffs on the price of raw materials used
manufacturing distribution
transformers.
a. Liquid-Immersed Transformers
Table II.10 and Table II.11
respectively contain material price data
for liquid-immersed distribution
transformers relied upon in the April
2013 standards rule.17
TABLE II.10—TYPICAL MANUFACTURER’S MATERIAL PRICES FOR LIQUID-IMMERSED DESIGN LINES FROM THE APRIL 2013
STANDARDS RULE
Item and description
2010 price
M6 core steel ...........................................................................................................................................................
M5 core steel ...........................................................................................................................................................
M4 core steel ...........................................................................................................................................................
M3 core steel ...........................................................................................................................................................
M3 Lite Carlite core steel ........................................................................................................................................
M2 core steel ...........................................................................................................................................................
M2 Lite Carlite core steel ........................................................................................................................................
ZDMH (mechanically-scribed core steel) ................................................................................................................
SA1 (amorphous)—finished core, volume production .............................................................................................
Copper wire, formvar, round #10–20 ......................................................................................................................
Copper wire, enameled, round #7–10 .....................................................................................................................
Copper wire, enameled, rectangular sizes ..............................................................................................................
Aluminum wire, formvar, round #9–17 ....................................................................................................................
Aluminum wire, formvar, round #7–10 ....................................................................................................................
Copper strip, thickness range 0.02–0.045 ..............................................................................................................
Copper strip, thickness range 0.030–0.060 ............................................................................................................
Aluminum strip, thickness range 0.02–0.045 ..........................................................................................................
Aluminum strip, thickness range 0.045–0.080 ........................................................................................................
Kraft insulating paper with diamond adhesive ........................................................................................................
Mineral oil ................................................................................................................................................................
Tank Steel ................................................................................................................................................................
2011 price
1.33
1.38
1.45
1.88
1.95
2.00
2.10
2.05
2.38
4.87
4.84
4.97
3.07
2.57
4.97
4.97
2.08
2.08
1.52
3.35
0.38
1.04
1.10
1.20
1.30
1.95
1.40
2.10
1.90
2.20
4.87
4.84
4.97
3.07
2.57
4.97
4.97
2.08
2.08
1.52
3.35
0.38
TABLE II.11—SUMMARY TABLE OF FIXED MATERIAL COSTS FOR LIQUID-IMMERSED UNITS FROM THE APRIL 2013
STANDARDS RULE
Item and description
DL1
High voltage bushings .........................................................
Low voltage bushings ..........................................................
Core clamp, nameplate, and misc. hardware ......................
Transformer tank average cost * ..........................................
Issue D.5: DOE requests comment on
the prices of materials and labor used to
construct liquid-immersed distribution
transformers, including all grades of
electrical steel, that are presented in
section II.D.2.a. Such data may include
DL2
$28
$30
41.65
∼143
DL3
$6
$8
19.15
∼73
data both in absolute terms and
expressed relative to the 2010 and 2011
estimates from the April 2013 standards
rule.
DL4
$6
$60
50.65
∼629
DL5
$21
$24
75.65
∼389
$60
$160
105.65
∼1,016
b. Dry-Type Transformers
Table II.12 and Table II.13
respectively contain material cost data
for dry-type distribution transformers
relied upon in the April 2013 standards
rule.18
TABLE II.12—MANUFACTURER’S MATERIAL PRICES FOR DRY-TYPE DESIGN LINES FROM THE APRIL 2013 STANDARDS
RULE
jbell on DSK3GLQ082PROD with PROPOSALS
Item and description
2010 price
M36 core steel (26 gauge) ......................................................................................................................................
M19 core steel (26 gauge) ......................................................................................................................................
M12 core steel .........................................................................................................................................................
M6 core steel ...........................................................................................................................................................
M5 core steel ...........................................................................................................................................................
M4 core steel ...........................................................................................................................................................
M3 core steel ...........................................................................................................................................................
17 Materials prices for liquid-immersed
distribution transformers were not presented in the
final rule Federal Register notice, but can be found
on page 5–42 of chapter 5 of the April 2013
standards rule Technical Support Document,
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document?D=EERE-2010-BT-STD-0048-0760.
18 Materials prices for dry-type transformers were
not presented in the final rule Federal Register
notice, but can be found on page 5–44 of chapter
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0.60
0.83
0.95
1.33
1.38
1.45
1.88
2011 price
0.66
0.91
0.78
1.04
1.10
1.20
1.30
5 of the April 2013 standards rule Technical
Support Document, available from: https://
www.regulations.gov/document?D=EERE-2010-BTSTD-0048-0760.
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TABLE II.12—MANUFACTURER’S MATERIAL PRICES FOR DRY-TYPE DESIGN LINES FROM THE APRIL 2013 STANDARDS
RULE—Continued
Item and description
2010 price
M2 core steel ...........................................................................................................................................................
H–0 DR core steel (laser-scribed) ...........................................................................................................................
SA1 (amorphous)—finished core, volume production .............................................................................................
Copper wire, rectangular 0.1 × 0.2, Nomex wrapped .............................................................................................
Aluminum wire, rectangular 0.1 × 0.2, Nomex wrapped .........................................................................................
Copper strip, thickness range 0.02–0.045 ..............................................................................................................
Aluminum strip, thickness range 0.02–0.045 ..........................................................................................................
Nomex insulation (per pound) .................................................................................................................................
Cequin insulation (per pound) .................................................................................................................................
Impregnation (per gallon) ........................................................................................................................................
Winding Combs (per pound) ...................................................................................................................................
Enclosure Steel (per pound) ....................................................................................................................................
2011 price
2.00
2.06
2.38
4.52
2.97
4.97
2.08
24.50
5.53
22.55
12.34
0.38
1.40
1.70
2.20
4.52
2.97
4.97
2.08
24.50
5.53
22.55
12.34
0.38
TABLE II.13—SUMMARY TABLE OF FIXED MATERIAL COSTS FOR DRY-TYPE UNITS FROM THE APRIL 2013 STANDARDS
RULE
DL
$6
Item
LV and HV terminals (set) ...........
HV terminal board(s) ....................
LV bus-bar ...................................
Core/coil mounting frame .............
Additional Bracing ........................
Nameplate ....................................
Dog-bone duct spacer (ft.) ...........
Winding combs (lb.) .....................
Misc. hardware .............................
Enclosure (12, 14 gauge) ............
DL
$7
4
n/a
n/a
9.25
n/a
0.65
0.24
n/a
4.50
∼50
Issue D.6: DOE requests comment on
the prices of materials used to construct
dry-type distribution transformers,
including all grades of electrical steel,
that are presented in section II.D.2.b.
n/a
27
10.50
19
n/a
0.65
0.32
n/a
7
∼90
DL
$8
n/a
27
22.50
36
n/a
0.65
0.42
n/a
12
∼100
DL
$9
75
27
80
36
n/a
0.65
0.42
n/a
25
∼135
DL
$10
120
27
140
120
∼230
0.65
0.52
n/a
42
∼400
Such data may include data both in
absolute terms and expressed relative to
the 2010 and 2011 estimates from the
April 2013 standards rule.
DL
$11
DL
$12
100
27
80
42
n/a
0.65
0.42
10.00
32
∼200
DL
$13A
135
27
192
125
∼270
0.65
0.56
10.00
54
∼450
115
27
100
50
n/a
0.65
0.42
10.00
36
∼200
DL
$13B
150
27
270
175
∼330
0.65
0.60
10.00
60
∼450
c. Labor Markups
Table II.14 contains labor cost data for
both liquid-immersed and dry-type
manufacturers relied upon in the April
2013 standards rule.19
TABLE II.14—LABOR MARKUPS FOR LIQUID-IMMERSED AND DRY-TYPE MANUFACTURERS
Item description
Markup
percentage
Labor cost per hour * ...............................................................................................................................................
Indirect Production ** ...............................................................................................................................................
Overhead *** ............................................................................................................................................................
Fringe † ....................................................................................................................................................................
Assembly Labor Up-time †† .....................................................................................................................................
Fully-Burdened Cost of Labor .................................................................................................................................
........................
33
30
24
43
25
Rate per
hour ($)
16.80
22.35
29.05
36.03
51.52
64.40
jbell on DSK3GLQ082PROD with PROPOSALS
* Cost per hour is from U.S. Census Bureau, 2007 Economic Census—Detailed Statistics, published October 2009. Data for NAICS code
3353111 ‘‘Power and distribution transformers, except parts’’ Production workers’ hours and wages.
** Indirect production labor (e.g., production managers, quality control) as a percent of direct labor on a cost basis. Navigant Consulting, Inc.
(NCI) estimate.
*** Overhead includes commissions, dismissal pay, bonuses, vacation, sick leave, and social security contributions. NCI estimate.
† Fringe includes pension contributions, group insurance premiums worker’s compensation. Source: U.S. Census Bureau, 2007 Economic Census—Detailed Statistics, published October 2009. Data for NAICS code 3353111 ‘‘Power and distribution transformers, except parts’’ Total fringe
benefits as a percent of total compensation for all employees (not just production workers).
†† Assembly labor up-time is a factor applied to account for the time that workers are not assembling units and/or reworking unsatisfactory
units. The markup of 43 percent represents a 70 percent utilization (multiplying by 100/70). NCI estimate.
Issue D.7: DOE requests comment on
the prices of labor used to construct
distribution transformers that are
presented in section II.D.2.c. of this
document. Such data may include data
both in absolute terms and expressed
relative to estimates from the April 2013
standards rule.
3. Load Loss Scaling
19 Labor markups were not presented in the final
rule Federal Register notice, but can be found on
page 5–49 of chapter 5 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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Currently, DOE energy conservation
standards apply only at a single per-unit
load (PUL) value for a given distribution
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transformer equipment class (e.g., 50%
for liquid-immersed). 10 CFR 431.196.
However, distribution transformers
exhibit varying efficiency with varying
PUL.
Distribution transformer loss is
commonly separated into ‘‘load’’ and
‘‘no-load’’ components. The former is
often approximated as a quadratic
function of PUL, i.e., load losses grow in
proportion to the square of PUL. 78 FR
23372. Transformers in service may
deviate from this simplified assumption
for a variety of reasons (e.g., temperature
rise) and DOE is requesting comment on
the nature and magnitude of that
deviation.
Issue D.8: DOE requests comment on
how load losses vary as a function of
per-unit load. Specifically, DOE seeks
mathematical characterizations of load
losses, expressed as a function of PUL.
DOE is especially interested in learning
about formulas that may be more
accurate than the widely used quadratic
approximation, and explanations of the
bases of those formulas.
E. Distribution Channels
In generating end-user price inputs for
the life-cycle cost (‘‘LCC’’) analysis and
national impact analysis (‘‘NIA’’), DOE
must identify distribution channels (i.e.,
how the products are distributed from
the manufacturer to the consumer), and
estimate relative sales volumes through
each channel Markups depend on the
distribution channels for the different
equipment classes and consumer types,
for both new construction and
replacement equipment. In the April
2013 standards rule, DOE characterized
these distribution channels as described
in the following sections and shown in
Table II.15 of this document.
1. Liquid-Immersed Distribution
Transformers
DOE assumed for liquid-immersed
distribution transformers sold to
investor-owned utilities (IOUs) that 82
percent of sales were direct from the
manufacturer to a utility consumer
through a national account, and the
remaining 18 percent of sales were
through a transformer distributor.20 78
FR 23371. For liquid-immersed
distribution transformers sold to
publicly owned utilities, DOE assumed
that all sales were through a transformer
distributor.21
2. Dry-Type Distribution Transformers
In the April 2013 rule, DOE assumed
dry-type distribution transformers were
installed by an electrical contractor. An
electrical contractor usually purchases
the distribution transformer from a
distributor, and in this case, DOE
assumed it was appropriate to include a
contractor markup.
TABLE II.15—DISTRIBUTION CHANNELS FOR DISTRIBUTION TRANSFORMERS
Consumer
Liquid-immersed ......................
Investor-owned utility ..............
LVDT .......................................
Publicly-owned utility ..............
All ............................................
82
18
100
100
MVDT ......................................
All ............................................
100
Distribution channel
Manufacturer
Manufacturer
Manufacturer
Manufacturer
sumer.
Manufacturer
sumer.
As part of the rulemaking process,
DOE conducts an energy use analysis to
identify how products are used by
consumers, and thereby determine the
energy savings potential of energy
efficiency improvements. The energyuse analysis produces energy use
estimates and end-use load shapes for
distribution transformers. The energy
use estimates enable evaluation of
energy savings from the operation of
distribution transformers at various
efficiency levels, while the end-use load
characterization allows evaluation of the
impact on monthly and peak demand
for electricity.
The energy used by distribution
transformers is characterized by two
types of losses. The first are no-load
losses, which are also known as core
losses. No-load losses are roughly
constant and exist whenever the
transformer is energized (i.e., connected
to live power lines). The second are load
losses, which are also known as
resistance or I2R losses. Load losses
generally vary with the square of the
PUL being served by the transformer.
DOE is considering using the same
methodology for its energy-use analysis
as it did in the April 2013 standards
20 A more detailed discussion can be found on
page 6–7 of chapter 6 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
21 Distribution channels are discussed in detail on
page 6–1 of chapter 6 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
Issue E.1: DOE seeks input from
stakeholders on whether the
distribution channels described above
continue to accurately describe the
distribution chain for distribution
transformers and are sufficient to
describe the distribution market.
Issue E.2: DOE seeks input on the
percentage of equipment distributed
through the different distribution
channels, and whether the share of
equipment through each channel varies
based on equipment capacity, or
number of phases, or other equipment
characteristics.
F. Energy Use Analysis
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Market share
(%)
Type
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(National Account) → Consumer.
→ Distributor → Consumer.
→ Distributor → Consumer.
→ Distributor → Electrical contractor → Con→ Distributor → Electrical contractor → Con-
rule, where it assumed the following: (1)
Application of distribution transformers
vary significantly by transformer type
(liquid-immersed or dry-type) and
ownership; (2) electric utilities own
approximately 95 percent of liquidimmersed transformers; and (3)
commercial/industrial (C&I) entities use
mainly dry-type distribution
transformers. To account for the
differences in transformer application,
in the April 2013 standards rule, DOE
performed two separate end-use load
analyses to evaluate distribution
transformer efficiency, as described in
the following sections.22 78 FR 23372.
1. Hourly Load Analysis
The hourly load analysis for liquidimmersed distribution transformers
used two types of information related to
electric utilities. The first was drawn
from the Energy Information
Administration’s (EIA’s) Form 861
22 The energy-use analysis is discussed in detail
in Chapter 7 and Appendix 7A of the April 2013
standards rule Technical Support Document,
available from: https://www.regulations.gov/
document?D=EERE-2010-BT-STD-0048-0760.
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database.23 Form 861 provides, through
its Form 2, the annual sales in
megawatt-hours for each utility to the
residential, commercial, and industrial
sectors. Form 861’s Form 4 lists all the
utilities that own electricity distribution
equipment, and the county in which
that equipment is located. Based on
those data, DOE created a consumer
sample of utilities that own transformers
and assigned a sample weight to each
based on the electricity sales of that
utility.
The second type of utility information
used is hourly system loads and prices.
DOE developed regional system loads
and prices for the set of regions defined
in the EIA National Energy Modeling
System (NEMS) Electricity Market
Module (EMM).24 The regions represent
both national reliability regions and,
where they exist, integrated wholesale
electricity markets. Each region in turn
comprises a number of electric utility
control area operators (CAOs), some of
which may also be utility companies.
DOE obtained hourly load and system
lambda data (for regions without
wholesale markets) or day-ahead market
price data (for market regions) from the
Federal Energy Regulatory Commission
(FERC) Form 714 database.25 DOE
aggregated the hourly data to produce
regional time series for the EMM
regions.26
From these data, DOE estimated the
loads on individual liquid-immersed
distribution transformers for both
residential and non-residential utility
consumers by creating hourly proxy
transformer loads. These resulted in the
initial (first year) RMS load for liquidimmersed transformers ranging from 34
and 40 percent for single- and threephase equipment, respectively.
Additionally, as in the April 2013
standards rule, DOE is considering
projecting the energy consumption for
distribution transformers into the future.
This projection included a 0.5 percent
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23 U.S.
Department of Energy-Energy Information
Administration. Form EIA–861: Annual Electric
Power Industry Database. (2008). at https://
www.eia.doe.gov/cneaf/electricity/page/
eia861.html.
24 Energy Information Administration—Office of
Integrated Analysis and Forecasting. The National
Energy Modeling System (NEMS): An Overview.
(U.S. Department of Energy, 2009). at https://
www.eia.doe.gov/oiaf/aeo/overview/.
25 U.S. Department of Energy-Federal Energy
Regulatory Commission. Form No. 714—Annual
Electric Control and Planning Area Report. (U.S.
Department of Energy-Federal Energy Regulatory
Commission, 2008). at https://www.ferc.gov/docsfiling/forms/form-714/overview.asp.
26 The hourly load analysis is discussed in detail
in Chapter 7 and Appendix 7A of the April 2013
standards rule Technical Support Document,
available from: https://www.regulations.gov/
document?D=EERE-2010-BT-STD-0048-0760.
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per-year load growth factor to account
for utility growth in the connected load
on liquid-immersed distribution
transformers, and no-load growth for
LVDT and MVDT transformers.27 78 FR
23375.
Issue F.1: DOE requests comment on
whether it should use the hourly load
analysis for liquid-immersed
distribution transformers relied upon in
April 2013 standards rule and what
updates to the inputs should be
considered. Included in the type of
information that DOE would find useful
are: (i) Sources of data and
recommendations to support an hourly
load model; (ii) data on utility-owned
distribution transformer hourly loads for
the liquid-immersed equipment classes
under consideration; (iii) field or
simulated energy use data or other
relevant information that could assist in
the development or calibration for its
hourly load analysis; (iv) data and
information supporting or refuting the
assumption that larger capacity liquidimmersed transformers are loaded to a
higher degree than smaller capacity
liquid-immersed transformers, and; (v)
any other data commenters believe
would be relevant.
Issue F.2: DOE requests comment on
the appropriateness of its prior
assumption of future load growth.
Examples of information requested
include, but are not limited to, sources
of data or recommendation to support to
an annual load growth assumption, and
information on whether the growth of
connected loads would vary with
geography, transformer type, capacity,
or phase-count.
a. Utilities Serving Low Population
Densities
DOE recognizes that in rural areas, the
number of utility customers per
distribution transformer is likely to be
significantly lower than in urban or
suburban areas, which in turn results in
lower PULs. DOE is considering using
the same methodology that it used in
the April 2013 standards rule, where the
PUL was reduced by 10 percent for
utilities serving counties with less than
32 households per square mile.28
Issue F.3: DOE seeks comment on the
continued appropriateness of the
27 A more detailed discussion can be found on
page 8–25 of chapter 8 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
28 PUL estimates for utilities serving low
population densities were not presented in the final
rule Federal Register notice, but can be found on
page 8–16 of chapter 8 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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adjustment to the PUL for areas with
low population density, including
information and data as to the PULs
experienced by transformers in-service
in low population density areas.
2. Monthly Load Analysis
The consumer sample for the monthly
load analysis used for LVDT and MVDT
distribution transformer owners was
taken from the EIA’s Commercial
Buildings Energy Consumption Survey
(CBECS) databases.29 Survey data for
the years 1992 and 1995 were used, as
these are the only years for which
monthly consumer electricity
consumption (kWh) and peak demand
(kW) are provided. To account for
changes in the distribution of building
floor space by building type and size,
the weights defined in the 1992 and
1995 building samples were rescaled to
reflect the distribution in the 2012
CBECS survey. CBECS covers primarily
commercial buildings, but a significant
fraction of transformers are shipped to
industrial building owners. To account
for this in the sample, data from the
EIA’s 2010 Manufacturing Energy
Consumption Survey (MECS) 30 was
used to estimate the amount of floor
space of buildings that might use the
type of transformer covered by the
rulemaking. The statistical weights
assigned to the building sample were
rescaled to reflect this additional floor
space.
From these data, in the April 2013
standards rule, DOE estimated that on
average, the RMS PUL for LVDT
transformers ranged from 20 and 25
percent for commercial and industrial
consumers, respectively;31 and that, on
average, the RMS PUL for MVDT
transformers ranged from 32 and 38
percent for commercial and industrial
consumers, respectively.32
Issue F.4: DOE requests comment on
the methodology for determining
monthly loads for LVDT and MVDT
29 Commercial Building Energy Consumption and
Expenditures Survey (CBECS); 1992 and 1995; U.S.
Department of Energy—Energy Information
Administration; https://www.eia.doe.gov/emeu/
cbecs/microdat.html.
30 Manufacturing Energy Consumption Survey
(MECS); 2006 U.S. Department of Energy—Energy
Information Administration; https://www.eia.gov/
emeu/mecs/contents.html.
31 The result of DOE’s transformer load analysis
for LVDT distribution transformers are contained in
the Life-cycle Cost and Payback Period spreadsheet
tools for DLs 6 through 8 on the Forecast Cells tab.
(available at: https://www.regulations.gov/
document?D=EERE-2011-BT-STD-0051-0085)
32 The result of DOE’s transformer load analysis
for MVDT distribution transformers are contained
in the Life-cycle Cost and Payback Period
spreadsheet tools for DL 9 through 13B on the
Forecast Cells tab. (available at: https://
www.regulations.gov/document?D=EERE-2010-BTSTD-0048-0764)
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equipment classes relied upon in the
April 2013 standards rule and whether
DOE should consider changes to the
methodology.
Issue F.5: DOE requests comment on
the appropriateness of the data sources
relied upon for determining monthly
loads for LVDT and MVDT equipment
classes in the April 2013 standards rule
and whether additional sources should
be considered. Comments may include
field or simulated energy use data or
other relevant information that could
assist in the development or calibration
for its monthly load analysis.
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G. Life-Cycle Cost and Payback Period
Analysis
The purpose of the LCC and PBP
analyses is to evaluate the economic
impacts of potential energy conservation
standards on individual consumers. The
effect of new or amended energy
conservation standards on consumers
usually involves a reduction in
operating cost and an increase in
purchase cost.
DOE intends to analyze the potential
for variability by performing the LCC
and PBP calculations on a
representative sample of individual
consumers. DOE plans to utilize the
sample of buildings developed for the
energy use analysis and the
corresponding simulation results.33
DOE plans to model uncertainty in
many of the inputs to the LCC and PBP
analysis using Monte Carlo simulation
and probability distributions. As a
result, the LCC and PBP results will be
displayed as distributions of impacts
compared to the no-new-standards case
(without amended standards)
conditions.
Issue G.1: DOE requests comment on
the overall methodology that it intends
to use to conduct the LCC and PBP
analysis for distribution transformers.
1. Base-Case Efficiency Distributions
To determine an appropriate base case
against which to compare various
potential standard levels, in the April
2013 standards rule DOE incorporated
in the LCC calculations a purchasedecision model that specifies which of
the hundreds of designs from the
engineering database are likely to be
selected by transformer purchasers to
meet a given efficiency level. The
engineering analysis yielded a costefficiency relationship in the form of
MSPs, no-load losses, and load losses
for a wide range of realistic transformer
designs. This set of data provides the
33 DOE plans to utilize the utility information
from EIA-Form 851 and FERC No. 714, commercial,
and manufacturing building types defined in
CEBCS and MECS databases.
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LCC model with a distribution of
transformer design choices.
If it determines that a rulemaking is
necessary, DOE plans on using the same
approach as in the April 2013 standards
rule that employs the selection criteria
known in the transformer industry as
total owning cost (TOC). The TOC
method combines transformer first costs
with the consumer’s cost of losses to
produce a present value of losses over
the lifetime of a transformer. Consumers
of distribution transformers, especially
in the utility sector, have long used the
TOC method to determine which
transformers to purchase. DOE refers to
those consumers who employ the TOC
method to determine which transformer
to purchase in the context of the LCC as
‘‘evaluators’’.
In the April 2013 standards rule, DOE
assumed the following fraction of
consumers to be evaluators: 10 percent
for liquid-immersed transformers, and 2
percent for both LVDT and MVDT
transformers. DOE assumed the fraction
of evaluators to select a transformer
with the best TOC for their cost of losses
(this was usually of higher efficiency
than the baseline), while the remaining
consumers, who were not considered
evaluators, selected new distribution
transformers at the baseline efficiency.34
78 FR 23374.
Issue G.2: DOE seeks information on
the fraction of consumers who employ
an evaluation methodology, such as the
Total Owning Cost methodology,35 36
that may lead to transformer purchases
at a cost greater than lowest-first-costs.
Further, DOE seeks information on
whether this changes with the size of
consumer (in terms of peak demand), or
by equipment class or equipment
capacity.
Issue G.3: DOE seeks information on
the fraction of consumers who purchase
LVDT transformers at efficiencies at, or
greater than, those specified under the
NEMA Premium Efficiency Transformer
Program.37
2. Installation Costs
The primary inputs for establishing
the total installed cost are the baseline
34 The transformer selection approach is
discussed in detail in chapter 8 of the April 2013
standards rule Technical Support Document,
available from: https://www.regulations.gov/
document?D=EERE-2010-BT-STD-0048-0760.
35 IEEE, Loss Evaluation Guide for Power
Transformers and Reactors, 1992, DOI: 10.1109/
IEEESTD.1992.114388.
36 United States Department Of Agriculture: Rural
Utilities Services, Guide for Economic Evaluation of
Distribution Transformers, August 2016, RUS
Bulletin 1724D–107, See: https://www.rd.usda.gov/
files/UEP_Bulletin_1724D-107.pdf.
37 See: https://www.nema.org/Technical/Pages/
NEMA-Premium-Efficiency-TransformersProgram.aspx
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consumer price, standard-level
consumer price increases, and
installation costs. Baseline transformer
prices and standard-level transformer
price increases will be determined by
applying markups to MSP estimates.
a. Impact of Increased Distribution
Transformer Weight on Installation
Costs
Total installed costs for distribution
transformers dependent heavily on the
weight of the equipment. DOE plans to
derive the weight-versus-capacity
relationship for a typical distribution
transformer from the design data
produced by the engineering analysis as
it did in the April 2013 standards rule.
DOE estimated a scaling relationship
between transformer weight, and direct
installation labor and equipment costs
from RSMeans for the electrical
equipment categories: ‘‘dry-type
transformer’’, ‘‘oil-filled transformer’’,
and ‘‘transformer, liquid-filled’’.38
Issue G.4: DOE seeks information and
data on the installation cost versus
transformer weight relationship for the
different types of transformers and
capacities under consideration.
b. Estimation of Pole Replacement Costs
In addition to including installation
costs that scale with transformer weight,
DOE is considering including costs to
account for the rare occasion that a more
efficient pole-mounted replacement
transformer may require the installation
of a new, higher-grade, utility pole to
support any increase in weight due to
increased transformer efficiency.39 If it
determines that a rulemaking is
necessary, DOE plans to use the same
methodology it used in the April 2013
standards rule, where the polereplacement cost function was applied
to those modelled design lines that
included pole-mounted distribution
transformers.40 78 FR 23374.
38 See page 6–2 of chapter 6 of the April 2013
standards rule Technical Support Document for a
more detailed discussion on transformer
installation costs, available from: https://
www.regulations.gov/document?D=EERE-2010-BTSTD-0048-0760.
39 In the April 2013 standards rule DOE estimated
an average relative increase in transformer weight
when compared to baseline equipment to be
between 14 percent and 4 percent for DL 2, and DL
3, respectively. In absolute terms, the average
weight increase was between 48 lbs. and 120 lbs.
for DL 2, and DL3, respectively. The results of
DOE’s pole replacement analysis for pole-mounted
liquid-immersed distribution transformers are
contained in the Life-cycle Cost and Payback Period
spreadsheet tools for DL 2 and DL 3 on the Forecast
Cells tab. (available at: https://www.regulations.gov/
document?D=EERE-2010-BT-STD-0048-0767)
40 See page 6–2 of chapter 6 of the April 2013
standards rule Technical Support Document for a
more detailed discussion on transformer
installation costs, available from: https://
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The degree of weight increase
depends on how a transformer design is
modified to improve efficiency. For
pole-mounted transformers (represented
by design lines 2 and 3 in the April
2013 standards rule), the increased
weight may lead to situations where the
pole needs to be upgraded to support
the additional weight of the transformer,
which in turn, leads to an increase in
the installation cost.
The methodology employed in the
April 2013 standards rule established
the threshold change in weight of the
transformer between the no-new
standards case and standard case level
that would trigger the need to upgrade
the utility pole to support the new more
efficient transformer. DOE assumed that
a pole change-out would only be
necessary if the weight increase was
greater than 15 percent of the base case
and was also 150 pounds heavier than
the weight of the base case unit for a25
kVA unit. To determine the weightchange threshold for larger capacity
units (i.e., 500kVA), the 150-pound
threshold was scaled using the 0.75
scaling rule 41 to 1,418 pounds. In some
cases, utilities have the option to
reinforce pole or structures with guy
wires instead of outright pole
replacement. Because of the general
practice of over-sizing of utility poles
for safety reasons, and the availability of
other supporting options, DOE limited
the total fraction of pole replacements to
25 percent of the total population. 78 FR
23374–23375
Issue G.5: DOE seeks comment on its
prior approach to accounting for the
need for pole replacement, including
data on the rate of pole change-out that
is driven by the increased weight of
more efficient distribution transformers
of the same capacity.
The cost of pole replacement typically
involves the removal of the old pole and
its disposal, erection of the upgraded
replacement pole, and the transferring
of all attached equipment and
concessions. DOE plans on using the
labor and equipment cost estimates from
the RSMeans, to construct a distribution
of possible costs paid by a utility when
performing a pole replacement for single
pole, and multi-pole (platform)
replacements.
Issue G.6: DOE seeks comment on its
understanding of utility pole upgrades
that result from an increase in
transformer weight; the continued
www.regulations.gov/document?D=EERE-2010-BTSTD-0048-0760.
41 The 0.75 Scaling Rule holds that for similarly
designed transformers, costs of construction and
losses scale with the ratio of their kVA ratings
raised to the 0.75 power. See 78 FR 23369 for a
more detailed description of the 0.75 Scaling Rule.
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appropriateness of this consideration,
including but not limited to information
and data on the rate of pole change-out
and on the cost of pole replacement by
transformer capacity.
Issue G.7: DOE seeks information on
any other factors that would impact
transformer installations costs due to an
increase in transformer efficiency.
3. Electricity Prices
DOE plans to estimate electricity
prices and costs to place a value on
transformer losses using the same
methodologies it used in the April 2013
standards rule. One hourly methodology
captured the nature of regional hourly
transformer loads, their correlation with
the overall utility system load, and their
correlation with hourly electricity costs
and prices. The monthly methodology
estimated the impacts of transformer
loads and resultant losses on monthly
electricity usage, demand, and
electricity bills. DOE plans to use the
hourly analysis for liquid-immersed
transformers, which are owned
predominantly by utilities that pay costs
that vary by the hour, and the monthly
analysis for dry-type transformers,
which typically are owned by
commercial and industrial
establishments that receive monthly
electricity bills.42 78 FR 73375–73377.
a. Hourly Electricity Costs
To evaluate the electricity costs
associated with liquid-immersed
distribution transformers, DOE plans to
use marginal electricity prices. Marginal
prices are those utilities pay for the last
kilowatt-hour of electricity produced
and may be higher or lower than the
average price, depending on the
relationships among capacity,
generation, transmission, and
distribution costs. The general structure
of the hourly marginal cost methodology
divides the costs of electricity into
capacity components and energy cost
components. For each component, the
economic value for both no-load losses
and load losses is estimated. The
capacity components include generation
and transmission capacity; it also
includes a reserve margin for ensuring
system reliability, with factors that
account for system losses. Energy cost
components include a marginal cost of
supply that varies by the hour.
DOE plans on using a marginal costs
methodology for the set of EMM regions.
To calculate the hourly price of
electricity, DOE plans on using the day42 A more detailed discussion can be found on
page 8–17 of chapter 8 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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ahead market clearing price for regions
having wholesale electricity markets,
and system lambda values for all other
regions. System lambda values, which
are roughly equal to the operating cost
of the next unit in line for dispatch, are
filed by control area operators under
FERC Form 714. DOE plans on using the
most recent data available for both
market prices and system lambdas.
Issue G.8: DOE seeks comment on its
approach for developing hourly
electricity prices, as well as additional
sources of relevant data.
b. Monthly Electricity Costs
To evaluate the electricity costs
associated with LVDT and MVDT
distribution transformers, DOE plans to
derive nationally representative
distributions of annual electricity prices
for different consumer categories
(industrial, commercial, and residential)
from the most recent data available in
the EIA Form 861, ‘‘Annual Electric
Power Industry Report,’’ as well as data
from the Edison Electric Institute.43
Issue G.9: DOE seeks comment on its
approach for developing monthly
electricity prices as well as additional
sources of relevant data.
4. Future Electricity Prices
DOE plans to use projections of
national average energy prices for
commercial and industrial consumers to
estimate future energy prices. DOE will
use the most recent available edition of
AEO as the default source of projections
for future energy prices.
Issue G.10: DOE seeks comment on its
consideration of future electricity prices
as well as additional relevant sources
for projecting future electricity prices.
H. Shipments
DOE develops shipments forecasts of
distribution transformers to calculate
the national impacts of potential
amended energy conservation standards
on energy consumption, net present
value (‘‘NPV’’), and future manufacturer
cash flows. DOE shipments projections
are based on available historical data
broken out by equipment class and
capacity. Current sales estimates allow
for a more accurate model that captures
recent trends in the market.
In the April 2013 standards rule, DOE
used sales estimates for the entire
market for distribution transformers for
years 2001 and 2009, disaggregated by
transformer type (liquid-immersed or
43 Edison Electric Institute. Typical Bills and
Average Rates Report. Washington, DC, October
2016.
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dry-type) and kVA rating.44 45 DOE
projected these shipments to future
years by assuming that annual
transformer shipments growth is equal
to growth in electricity consumption as
given by AEO 2012, and then
continuing this rate from 2030 to 2045.
DOE assumed that the market share of
transformers for each type, and at each
capacity, to be constant throughout the
analysis period. If DOE initiates an
energy conservation standards
rulemaking, DOE will consider using a
similar approach.46
Issue H.1: DOE seeks comment on its
approach to estimating current
shipments and future sales. Such
information may include, but need not
be limited to: (i) Data and information
on current and historical shipments and
market shares of distribution
transformers categories discussed in this
notice; (ii) data and information on the
distribution of shipments (in units) of
distribution transformers discussed in
this notice by rated capacity, type, BIL,
and installation application (polemounted, surface pad-mounted,
subsurface pad-mounted); and (iii) data
and information on how the distribution
of shipments of distribution
transformers discussed in this notice
has changed over time by rated capacity,
type, BIL, and installation application
(pole-mounted, surface pad-mounted,
subsurface pad-mounted).
Issue H.2: DOE requests comment on
the approach it intends on using to
develop the shipments model and
shipments forecasts for distribution
transformers under consideration for
potential standards.
1. Equipment Lifetimes
The equipment lifetime is the age at
which the equipment is retired from
service. DOE plans on using the same
approach that it used in the April 2013
standards rule, which was based on a
report by Oak Ridge National
Laboratory.47 It estimated that the
average life of a distribution transformer
is 32 years. This lifetime estimate
includes a constant failure rate of 0.5
percent/year due to lightning and other
random failures unrelated to
transformer age, and an additional
corrosive failure rate of 0.5 percent/year
starting at year 15. 78 FR 23377
Issue H.3: DOE seeks comments on its
approach for estimating equipment
lifetimes.
2. Purchase Price Elasticity and
Refurbished Transformers
DOE recognizes that increase in
transformer prices due to changes in
standards may cause changes in
purchases of new transformers. Due to
the essential nature of the utility
provided by a distribution transformer,
the option to forego purchase, or
substitute with other equipment, is very
limited. However, because the general
trend of utility transformer purchases is
determined by increases in generation,
utilities could conceivably exercise
some discretion in how much
transformer stock to buy—the amount of
‘‘over-capacity’’ to purchase and hold as
reserve stock, and may draw on these
reserves instead of purchasing new
equipment. In addition, some utilities
may choose to refurbish failed
transformers and return them to service,
rather than purchase a new transformer
if the price of the latter increases
significantly.
In the April 2013 standards rule, DOE
estimated the purchase price elasticity
at ¥0.04 for liquid-immersed
transformers, and ¥0.02 for all dry-type
transformers. To capture the negative
impact on the national energy saving
estimates of replacement refurbished
liquid-immersed transformers, DOE
assumed that the operational need for a
fraction of forgone purchases due to an
increase in price would be met with less
efficient refurbished equipment. DOE
assumed that 20 percent of these
foregone purchases would be met by
refurbished transformers; and that
refurbished transformers would have
shorter average lifetimes at 20 years, and
an efficiency of 70 percent, of baseline
transformers of the same capacity and
equipment class.48 78 FR 23379.
Issue H.4: DOE requests comment on
the purchase price elasticity values of
¥0.04 and ¥0.02 for liquid-immersed
and dry-type transformers, respectively.
Issue H.5: DOE requests comments on
the assumptions regarding consumer
response to amended standards made in
the April 2013 standards rule, including
but not limited to information and data
on the fraction and efficiency
characteristics of transformers that are
refurbished and are returned to service,
and whether the decision to use
refurbished equipment would vary with
equipment capacity, installation
application, or other circumstances.
The following tables of the types of
data requested for 2018 shipments in
can be found in Table II.16 and Table
II.17 of this document. Interested parties
are also encouraged to provide
additional shipment data as may be
relevant.
TABLE II.16—SUMMARY TABLE OF SINGLE-PHASE DISTRIBUTION TRANSFORMERS SHIPMENTS-RELATED DATA REQUESTS
[Units Shipped, 2018]
Liquid-immersed,
medium-voltage
kVA range
Dry-type, lowvoltage
Dry-type, mediumvoltage, 20–45 kV
BIL
Dry-type, mediumvoltage, 46–95 kV
BIL
Dry-type, mediumvoltage, ≥96 kV
BIL
10
15
25
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37.5
44 Hopkinson, P. & Puri, J. Distribution
Transformer Market Shipment Estimates for 2001.
(HVOLT Consultants Inc.: Washington DC, 2003).
45 Hopkinson, P. & Puri, J. Distribution
Transformer Market Shipment Estimates for 2009.
(HVOLT Consultants Inc.: Washington DC, 2010).
46 The market shares for distribution transformers
were not presented in the final rule Federal
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Register notice, but can be found on page 9–11 of
chapter 9 of the April 2013 standards rule
Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
47 Barnes. Determination Analysis of Energy
Conservation Standards for Distribution
Transformers. ORNL–6847. 1996.
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48 A more detailed discussion can be found on
page 9–14 of chapter 9 of the April 2013 standards
rule Technical Support Document, available from:
https://www.regulations.gov/document?D=EERE2010-BT-STD-0048-0760.
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28257
TABLE II.16—SUMMARY TABLE OF SINGLE-PHASE DISTRIBUTION TRANSFORMERS SHIPMENTS-RELATED DATA
REQUESTS—Continued
[Units Shipped, 2018]
Liquid-immersed,
medium-voltage
kVA range
Dry-type, lowvoltage
Dry-type, mediumvoltage, 20–45 kV
BIL
Dry-type, mediumvoltage, 46–95 kV
BIL
Dry-type, mediumvoltage, ≥96 kV
BIL
50
75
100
167
250
333
500
667
833
* BIL = basic impulse insulation level.
TABLE II.17—SUMMARY TABLE OF THREE-PHASE DISTRIBUTION TRANSFORMERS SHIPMENTS-RELATED DATA REQUESTS
[Units Shipped, 2018]
Liquid-immersed,
medium-voltage
kVA range
Dry-type, low-voltage
Dry-type, mediumvoltage, 20–45 kV
BIL
Dry-type, mediumvoltage, 46–95 kV
BIL
Dry-type, mediumvoltage, ≥96 kV
BIL
15
30
45
75
112.5
150
225
300
500
750
1000
1500
2000
2500
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* BIL = basic impulse insulation level.
If disaggregated fractions of annual
sales are not available at the equipment
type level, DOE requests more
aggregated fractions of annual sales at
the category level.
Issue H.6: If available, DOE requests
the same information in Table II.16 and
Table II.17 of this document for the
previous five years (2013 through 2017).
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I. Manufacturer Impact Analysis
The purpose of the manufacturer
impact analysis (‘‘MIA’’) is to estimate
the financial impact of amended energy
conservation standards on
manufacturers of distribution
transformers, and to evaluate the
potential impact of such standards on
direct employment and manufacturing
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capacity. The MIA includes both
quantitative and qualitative aspects. The
quantitative part of the MIA primarily
relies on the Government Regulatory
Impact Model (‘‘GRIM’’), an industry
cash-flow model adapted for the
equipment in this analysis, with the key
output of industry net present value
(‘‘INPV’’). The qualitative part of the
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MIA addresses the potential impacts of
energy conservation standards on
manufacturing capacity and industry
competition, as well as factors such as
equipment characteristics, impacts on
particular subgroups of firms, and
important market and equipment trends.
To account for manufacturers’ nonproduction costs and profit margin, DOE
applies a non-production cost multiplier
(the manufacturer markup) to the MPC.
The resulting MSP is the price at which
manufacturers sell their distribution
transformers to their first commercial
consumer along the distribution chain.
For the April 2013 standards rule, DOE
used a manufacturer markup of 1.25 for
all distribution transformer equipment
classes: liquid-immersed, LVDT and
MVDT.49
Issue I.1: DOE requests feedback on
whether a manufacturer markup of 1.25
is appropriate for all distribution
transformers.
As part of the MIA, DOE intends to
analyze impacts of amended energy
conservation standards on subgroups of
manufacturers of covered equipment,
including small business manufacturers.
DOE uses the Small Business
Administration’s (‘‘SBA’’) small
business size standards to determine
whether manufacturers qualify as small
businesses, which are listed by the
applicable North American Industry
Classification System (‘‘NAICS’’) code.50
Manufacturing of consumer distribution
transformers is classified under NAICS
335311, ‘‘Power, Distribution, and
Specialty Transformer Manufacturing,’’
and the SBA sets a threshold of 750
employees or less for a domestic entity
to be considered as a small business.
This employee threshold includes all
employees in a business’ parent
company and any other subsidiaries.
One aspect of assessing manufacturer
burden involves examining the
cumulative impact of multiple DOE
standards and the equipment-specific
regulatory actions of other Federal
agencies that affect the manufacturers of
a covered product or equipment. While
any one regulation may not impose a
significant burden on manufacturers,
the combined effects of several existing
or impending regulations may have
serious consequences for some
manufacturers, groups of manufacturers,
or an entire industry. Assessing the
impact of a single regulation may
49 Manufacturer markups were not presented in
the final rule Federal Register notice, but can be
found on pages 12–18 through 12–23 of the April
2013 standards rule Technical Support Document,
available from: https://www.regulations.gov/
document?D=EERE-2010-BT-STD-0048-0760.
50 Available online at https://www.sba.gov/
document/support-table-size-standards.
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overlook this cumulative regulatory
burden. In addition to energy
conservation standards, other
regulations can significantly affect
manufacturers’ financial operations.
Multiple regulations affecting the same
manufacturer can strain profits and lead
companies to abandon product lines or
markets with lower expected future
returns than competing products. For
these reasons, DOE conducts an analysis
of cumulative regulatory burden as part
of its rulemakings pertaining to
appliance efficiency.
Issue I.2: To the extent feasible, DOE
seeks the names and contact
information of any domestic or foreignbased manufacturers that distribute
distribution transformers in the United
States.
Issue I.3: DOE requests feedback on
the degree to which small businesses
perform core manufacturing techniques
themselves, such as assembly and
mitering, versus choosing to outsource,
and the corresponding effect on capital
investments required to achieve greater
efficiencies. DOE requests specific
comment on relative changes in these
practices relative to before the April
2013 standards rule.
Issue I.4: DOE identified small
businesses as a subgroup of
manufacturers that could be
disproportionally impacted by amended
energy conservation standards. DOE
requests the names and contact
information of small business
manufacturers, as defined by the SBA’s
size threshold, of distribution
transformers that distribute products in
the United States. In addition, DOE
requests comment on any other
manufacturer subgroups that could be
disproportionally impacted by amended
energy conservation standards. DOE
requests feedback on any potential
approaches that could be considered to
address impacts on manufacturers,
including small businesses.
Issue I.5: DOE requests information
regarding the cumulative regulatory
burden impacts on manufacturers of
distribution transformers associated
with (1) other DOE standards applying
to different products that these
manufacturers may also make and (2)
equipment-specific regulatory actions of
other Federal agencies. DOE also
requests comment on its methodology
for computing cumulative regulatory
burden and whether there are any
flexibilities it can consider that would
reduce this burden while remaining
consistent with the requirements of
EPCA.
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J. Other Energy Conservation Standards
Topics
1. Market Failures
In the field of economics, a market
failure is a situation in which the
market outcome does not maximize
societal welfare. Such an outcome
would result in unrealized potential
welfare. DOE welcomes comment on
any aspect of market failures, especially
those in the context of amended energy
conservation standards for distribution
transformers.
2. Emerging Smart Technology Market
DOE recently published an RFI on the
emerging smart technology appliance
and equipment market. 83 FR 46886
(Sept. 17, 2018). In that RFI, DOE sought
information to better understand market
trends and issues in the emerging
market for appliances and commercial
equipment that incorporate smart
technology. DOE’s intent in issuing the
RFI was to ensure that DOE did not
inadvertently impede such innovation
in fulfilling its statutory obligations in
setting efficiency standards for covered
products and equipment. DOE seeks
comments, data and information on the
issues presented in the RFI as they may
be applicable to distribution
transformers.
3. Other
In addition to the issues identified
earlier in this document, DOE welcomes
comment on any other aspect of energy
conservation standards for distribution
transformers not already addressed by
the specific areas identified in this
document.
III. Submission of Comments
DOE invites all interested parties to
submit in writing by August 2, 2019,
comments and information on matters
addressed in this document and on
other matters relevant to DOE’s
consideration of amended energy
conservations standards for distribution
transformers. After the close of the
comment period, DOE will review the
public comments received and may
begin collecting data and conducting the
analyses discussed in this RFI.
Submitting comments via https://
www.regulations.gov. The https://
www.regulations.gov web page requires
you to provide your name and contact
information. Your contact information
will be viewable to DOE Building
Technologies Office staff only. Your
contact information will not be publicly
viewable except for your first and last
names, organization name (if any), and
submitter representative name (if any).
If your comment is not processed
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properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment or in any documents
attached to your comment. Any
information that you do not want to be
publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Persons viewing comments will see only
first and last names, organization
names, correspondence containing
comments, and any documents
submitted with the comments.
Do not submit to https://
www.regulations.gov information for
which disclosure is restricted by statute,
such as trade secrets and commercial or
financial information (hereinafter
referred to as Confidential Business
Information (‘‘CBI’’)). Comments
submitted through https://
www.regulations.gov cannot be claimed
as CBI. Comments received through the
website will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section.
DOE processes submissions made
through https://www.regulations.gov
before posting. Normally, comments
will be posted within a few days of
being submitted. However, if large
volumes of comments are being
processed simultaneously, your
comment may not be viewable for up to
several weeks. Please keep the comment
tracking number that
www.regulations.gov provides after you
have successfully uploaded your
comment.
Submitting comments via email, hand
delivery/courier, or postal mail.
Comments and documents submitted
via email, hand delivery/courier, or
postal mail also will be posted to https://
www.regulations.gov. If you do not want
your personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information on a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. The cover
letter will not be publicly viewable as
long as it does not include any
comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. If you
submit via postal mail or hand delivery/
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courier, please provide all items on a
CD, if feasible. It is not necessary to
submit printed copies. No telefacsimiles
(faxes) will be accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are not
secured, written in English and free of
any defects or viruses. Documents
should not contain special characters or
any form of encryption and, if possible,
they should carry the electronic
signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
Confidential Business Information.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit via email, postal mail, or
hand delivery/courier two well-marked
copies: one copy of the document
marked confidential including all the
information believed to be confidential,
and one copy of the document marked
‘‘non-confidential’’ with the information
believed to be confidential deleted.
Submit these documents via email or on
a CD, if feasible. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
Factors of interest to DOE when
evaluating requests to treat submitted
information as confidential include: (1)
A description of the items, (2) whether
and why such items are customarily
treated as confidential within the
industry, (3) whether the information is
generally known by or available from
other sources, (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality, (5) an
explanation of the competitive injury to
the submitting person which would
result from public disclosure, (6) when
such information might lose its
confidential character due to the
passage of time, and (7) why disclosure
of the information would be contrary to
the public interest.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
information deemed to be exempt from
public disclosure).
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28259
DOE considers public participation to
be a very important part of the process
for developing energy conservation
standards. DOE actively encourages the
participation and interaction of the
public during the comment period in
each stage of the rulemaking process.
Interactions with and between members
of the public provide a balanced
discussion of the issues and assist DOE
in the rulemaking process. Anyone who
wishes to be added to the DOE mailing
list to receive future notices and
information about this process or would
like to request a public meeting should
contact Appliance and Equipment
Standards Program staff at (202) 287–
1445 or via email at
ApplianceStandardsQuestions@
ee.doe.gov.
Signed in Washington, DC, on June 11,
2019.
Daniel R. Simmons,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
[FR Doc. 2019–12761 Filed 6–17–19; 8:45 am]
BILLING CODE 6450–01–P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 300
[EPA–HQ–SFUND–1983–0002; FRL–9995–
25–Region 9]
National Oil and Hazardous
Substances Pollution Contingency
Plan; National Priorities List: Deletion
of the MGM Brakes Superfund Site
Environmental Protection
Agency (EPA).
ACTION: Proposed rule; notice of intent.
AGENCY:
SUMMARY: The Environmental Protection
Agency (EPA) Region 9 is issuing a
Notice of Intent to Delete MGM Brakes
Superfund Site (Site) located in
Cloverdale, Sonoma County, California,
from the National Priorities List (NPL)
and requests public comments on this
proposed action. The NPL, promulgated
pursuant to section 105 of the
Comprehensive Environmental
Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended, is
an appendix of the National Oil and
Hazardous Substances Pollution
Contingency Plan (NCP). The EPA and
the State of California, through the
Department of Toxic Substances
Control, have determined that all
appropriate response actions under
CERCLA have been completed.
However, this deletion does not
preclude future actions under
Superfund.
E:\FR\FM\18JNP1.SGM
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Agencies
[Federal Register Volume 84, Number 117 (Tuesday, June 18, 2019)]
[Proposed Rules]
[Pages 28239-28259]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-12761]
========================================================================
Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
========================================================================
Federal Register / Vol. 84, No. 117 / Tuesday, June 18, 2019 /
Proposed Rules
[[Page 28239]]
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2019-BT-STD-0018]
Energy Conservation Program: Energy Conservation Standards for
Distribution Transformers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Request for information.
-----------------------------------------------------------------------
SUMMARY: The U.S. Department of Energy (``DOE'') is initiating an
effort to determine whether to amend the current energy conservation
standards for distribution transformers. Under the Energy Policy and
Conservation Act of 1975, as amended, DOE must review these standards
at least once every six years and publish either a notice of proposed
rulemaking (``NOPR'') to propose new standards for distribution
transformers or a notice of determination that the existing standards
do not need to be amended. This request for information (``RFI'')
solicits information from the public to help DOE determine whether
amended standards for distribution transformers would result in
significant energy savings and whether such standards would be
technologically feasible and economically justified. DOE welcomes
written comments from the public on any subject within the scope of
this document (including topics not raised in this RFI).
DATES: Written comments and information are requested and will be
accepted on or before August 2, 2019.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at https://www.regulations.gov. Follow
the instructions for submitting comments. Alternatively, interested
persons may submit comments, identified by docket number EERE-2019-BT-
STD-0018, by any of the following methods:
1. Federal eRulemaking Portal: https://www.regulations.gov. Follow
the instructions for submitting comments.
2. Email: [email protected]. Include
the docket number EERE-2019-BT-STD-0018 in the subject line of the
message.
3. Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1445. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
4. Hand Delivery/Courier: Appliance and Equipment Standards
Program, U.S. Department of Energy, Building Technologies Office, 950
L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202)
287-1445. If possible, please submit all items on a CD, in which case
it is not necessary to include printed copies.
No telefacsimilies (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section III of this document.
Docket: The docket for this activity, which includes Federal
Register notices, comments, and other supporting documents/materials,
is available for review at https://www.regulations.gov. All documents in
the docket are listed in the https://www.regulations.gov index. However,
some documents listed in the index, such as those containing
information that is exempt from public disclosure, may not be publicly
available.
The docket web page can be found at https://www.regulations.gov/#docketDetail;D=EERE-2019-BT-STD-0018. The docket web page contains
instructions on how to access all documents, including public comments,
in the docket. See section III for information on how to submit
comments through https://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 586-9870. Email: [email protected].
Ms. Sarah Butler, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121.
Telephone: (202) 586-1777. Email: [email protected].
For further information on how to submit a comment or review other
public comments and the docket contact the Appliance and Equipment
Standards Program staff at (202) 287-1445 or by email:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Authority and Background
B. Rulemaking Process
C. Summary of the Impacts of the Amorphous Steel Market on the
Current Standards for Liquid-Immersed Distribution Transformers
D. Summary of the Impacts of the Steel Market on the Current
Standards for Low-Voltage Dry-Type Distribution Transformers
II. Request for Information and Comments
A. Equipment Covered by This Process
B. Market and Technology Assessment
1. Equipment Classes
2. Technology Assessment
3. Electrical Steel Market Assessment
C. Screening Analysis
D. Engineering Analysis
1. General Methodology
2. Price Inputs to Analysis
3. Load Loss Scaling
E. Distribution Channels
1. Liquid-Immersed Distribution Transformers
2. Dry-Type Distribution Transformers
F. Energy Use Analysis
1. Hourly Load Analysis
2. Monthly Load Analysis
G. Life-Cycle Cost and Payback Period Analysis
1. Base-Case Efficiency Distributions
2. Installation Costs
3. Electricity Prices
4. Future Electricity Prices
H. Shipments
1. Equipment Lifetimes
2. Purchase Price Elasticity and Refurbished Transformers
I. Manufacturer Impact Analysis
J. Other Energy Conservation Standards Topics
1. Market Failures
2. Emerging Smart Technology Market
3. Other
III. Submission of Comments
[[Page 28240]]
I. Introduction
A. Authority and Background
The Energy Policy and Conservation Act of 1975, as amended
(``EPCA''),\1\ among other things, authorizes DOE to regulate the
energy efficiency of a number of consumer products and certain
industrial equipment. (42 U.S.C. 6291-6317) Title III, Part C \2\ of
EPCA, added by Public Law 95-619, Title IV, section 441(a), established
the Energy Conservation Program for Certain Industrial Equipment, which
sets forth a variety of provisions designed to improve energy
efficiency. This equipment includes distribution transformers, the
subject of this RFI. Congress directed DOE to prescribe energy
conservation standards for such equipment. (42 U.S.C. 6317(a)(2))
Congress also established energy conservation standards for low-voltage
dry-type distribution transformers. (42 U.S.C. 6295(y))
---------------------------------------------------------------------------
\1\ All references to EPCA in this document refer to the statute
as amended through America's Water Infrastructure Act of 2018,
Public Law 115-270 (October 23, 2018).
\2\ For editorial reasons, upon codification in the U.S. Code,
Part C was redesignated Part A-1.
---------------------------------------------------------------------------
The energy conservation program under EPCA consists essentially of
four parts: (1) testing, (2) labeling, (3) Federal energy conservation
standards, and (4) certification and enforcement procedures. Relevant
provisions of EPCA include definitions (42 U.S.C. 6311), energy
conservation standards (42 U.S.C. 6313), test procedures (42 U.S.C.
6314), labeling provisions (42 U.S.C. 6315), and the authority to
require information and reports from manufacturers (42 U.S.C. 6316).
Federal energy efficiency requirements for covered equipment
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6316(a) and (b); 42 U.S.C. 6297)
On October 12, 2007, DOE established energy conservation standards
for liquid-immersed distribution transformers and medium-voltage, dry-
type (MVDT) distribution transformers. 72 FR 58190. The Energy Policy
Act of 2005 (Pub. L. 109-58, EPACT 2005) amended EPCA to establish
energy conservation standards for low-voltage dry-type (LVDT)
distribution transformers.3 4 (42 U.S.C. 6295(y)) On April
18, 2013, DOE amended the energy conservation standards for liquid-
immersed, MVDT, and LVDT distribution transformers.\5\ 78 FR 23335
(``April 2013 standards rule'').
---------------------------------------------------------------------------
\3\ EPACT 2005 established that the efficiency of a low-voltage
dry-type distribution transformer manufactured on or after January
1, 2007 shall be the Class I Efficiency Levels for distribution
transformers specified in Table 4-2 of the ``Guide for Determining
Energy Efficiency for Distribution Transformers'' published by the
National Electrical Manufacturers Association (NEMA TP 1-2002).
\4\ Although certain provisions pertaining to distribution
transformers, including test procedures and standards for LVDT
distribution transformers, have been established in the part of EPCA
generally applicable to consumer products (See, 42 U.S.C. 6291(35),
6293(b)(10), 6295(y)), they are commercial equipment. Accordingly,
DOE has established the regulatory requirements for distribution
transformers, including LVDT distribution transformers, in 10 CFR
part 431, Energy Efficiency Program for Certain Commercial and
Industrial Equipment. See, 70 FR 60407 (October 18, 2005).
\5\ The Technical Support Document for the April 2013 standards
rule is available at the following: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
The amended energy conservation standards in the April 2013
standards rule were informed by a series of negotiated rulemaking
sessions. DOE established subcommittees under DOE's Energy Efficiency
and Renewable Energy Advisory Committee (ERAC), in accordance with the
Federal Advisory Committee Act and the Negotiated Rulemaking Act, to
negotiate proposed standards for the energy efficiency of MVDT and
liquid-immersed distribution transformers, and LVDT distribution
transformers, separately. 76 FR 45471 (July 29, 2011); 76 FR 50148
(August 12, 2011). The ERAC subcommittees consisted of representatives
of parties with a defined stake in the outcome of the energy
conservation standards. The ERAC subcommittee held multiple meetings to
negotiate the energy conservation standards, wherein DOE presented both
draft and revised engineering, life-cycle cost and national impact
analyses and results, based on input from subcommittee members on a
number of topics. The resulting April 2013 standards rule was informed
by the content of the negotiation sessions. The negotiating committee
reached an outright consensus regarding energy conservation standards
for MVDT distribution transformers but not for liquid-immersed or LVDT
distribution transformers. 78 FR 23346-22347.
The current energy conservation standards are located in 10 CFR
431.196. The currently applicable DOE test procedures for distribution
transformers appear at 10 CFR part 431, subpart K, appendix A.
EPCA also requires that, not later than 6 years after the issuance
of any final rule establishing or amending a standard, DOE must
evaluate the energy conservation standards for each type of covered
equipment, including those at issue here, and publish either a notice
of determination that the standards do not need to be amended based on
the criteria established under 42 U.S.C. 6295(n)(2), or a NOPR
including new proposed energy conservation standards based on the
criteria at 42 U.S.C. 6295(o). (42 U.S.C. 6316(a); 42 U.S.C.
6295(m)(1))
If DOE determines not to amend a standard based on the statutory
criteria, not later than 3 years after the issuance of a final
determination not to amend standards, DOE must publish either a new
determination that standards for the product do not need to be amended,
or a NOPR including new proposed energy conservation standards. (42
U.S.C. 6316(a); 42 U.S.C. 6295(m)(3)(B)) If DOE decides to amend the
standard based on the statutory criteria, DOE must publish a final rule
not later than two years after energy conservation standards are
proposed. (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(3)(A))
DOE must publicize its analysis and determination to not amend
standards or to propose standards and provide an opportunity for
written comment. (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(2)) In making
either determination, DOE must evaluate whether more stringent
standards would (1) result in significant conservation of energy and
(2) be both technologically feasible and economically justified. (42
U.S.C. 6316(a); 42 U.S.C. 6295(m)(1)(A)).
DOE is publishing this RFI to collect data and information to
inform its decision consistent with its obligations under EPCA.
B. Rulemaking Process
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered equipment. EPCA requires that any new or
amended energy conservation standard be designed to achieve the maximum
improvement in energy or water efficiency that is technologically
feasible and economically justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(A)) To determine whether a standard is economically
justified, EPCA requires that DOE determine whether the benefits of the
standard exceed its burdens by considering, to the greatest extent
practicable, the following seven factors:
(1) The economic impact of the standard on the manufacturers and
consumers of the affected products;
(2) The savings in operating costs throughout the estimated average
life of the product compared to any increases in the initial cost, or
maintenance expenses;
(3) The total projected amount of energy and water (if applicable)
savings
[[Page 28241]]
likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the products
likely to result from the standard;
(5) The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(I)-()
thrVII)).
DOE fulfills these and other applicable requirements by conducting
a series of analyses throughout the rulemaking process. Table I.1 shows
the individual analyses that are performed to satisfy each of the
requirements within EPCA.
Table I.1-- EPCA Requirements and Corresponding DOE Analysis
------------------------------------------------------------------------
EPCA requirement Corresponding DOE analysis
------------------------------------------------------------------------
Technological feasibility.............. Market and Technology
Assessment.
Screening Analysis.
Engineering Analysis.
Economic Justification: ...............................
1. Economic impact on manufacturers and Manufacturer Impact
consumers. Analysis.
Life-Cycle Cost and
Payback Period Analysis.
Life-Cycle Cost
Subgroup Analysis.
Shipments Analysis.
2. Lifetime operating cost savings Markups for Product
compared to increased cost for the Price Determination.
product.
Energy and Water Use
Determination.
Life-Cycle Cost and
Payback Period Analysis.
3. Total projected energy savings...... Shipments Analysis.
National Impact
Analysis.
4. Impact on utility or performance.... Screening Analysis.
Engineering Analysis.
5. Impact of any lessening of Manufacturer Impact
competition. Analysis.
6. Need for national energy and water Shipments Analysis.
conservation.
National Impact
Analysis.
7. Other factors the Secretary Employment Impact
considers relevant. Analysis.
Utility Impact
Analysis.
Emissions Analysis.
Monetization of
Emission Reductions Benefits.
Regulatory Impact
Analysis.
------------------------------------------------------------------------
As detailed throughout this RFI, DOE is publishing this document
seeking input and data from interested parties to aid in the
development of the technical analyses on which DOE will ultimately rely
to determine whether (and if so, how) to amend the standards for
distribution transformers.
C. Summary of the Impacts of the Amorphous Steel Market on the Current
Standards for Liquid-Immersed Distribution Transformers
In the April 2013 standards rule, DOE set energy conservation
standards for liquid-immersed distribution transformers, LVDT
distribution transformers, and MVDT distribution transformers. 75 FR
23338. In its analyses of liquid-immersed distribution transformers,
DOE considered seven sets of energy efficiency levels, referred to as
trial standard levels (``TSL''). The levels represent increasingly
stringent levels of energy conservation standards, numbered from TSL 1,
the least stringent, to TSL 7, the most stringent. 78 FR 23397. DOE
adopted TSL 1 energy conservation levels for liquid-immersed
distribution transformers. DOE did not adopt energy efficiency levels
more stringent than TSL 1 in part because of risks associated with
limitations in the available supply of amorphous steel. At more
stringent required standard levels DOE determined it likely that the
market would transition entirely to the use of amorphous steel. 78 FR
23415-23418. DOE was concerned that if this were the case, there might
not have been a sufficient supply of amorphous steel to meet
manufacturers' needs. Id.
DOE determined that the burden of the risk that manufacturers would
not be able to obtain the quantities of amorphous steel required to
meet the higher efficiency requirement levels outweighed the benefits
of adopting these efficiency levels. Id. This determination contributed
to DOE's decision that the higher efficiency requirement levels were
not economically justified. Id. Additionally, DOE acknowledged that
although the industry could manufacture liquid-immersed distribution
transformers at TSL 2 and TSL 3 from steels other than amorphous steel,
amorphous steel was the cheapest design option for at least some of the
transformer designs that were analyzed at these levels. 78 FR 23417-
23418. In the analysis that led up to the April 2013 standards rule,
DOE identified only one supplier that produced amorphous steel in any
significant volume. DOE expressed concern that this one supplier,
together with others that might enter the market, would not be able to
increase production of amorphous steel rapidly enough to supply the
amounts that would be needed by transformer manufactures before the
compliance date of January 1, 2016, if any energy efficiency levels
higher than TSL 1 were adopted. 78 FR 23414-23421
D. Summary of the Impacts of the Steel Market on the Current Standards
for Low-Voltage Dry-Type Distribution Transformers
In its analyses of low-voltage dry-type distribution transformers
for the April 2013 standards rule, DOE considered six sets of trial
standard levels with increasingly stringent levels of energy
conservation standards and adopted TSL 2 energy conservation levels. 78
FR 23337. DOE did not adopt energy efficiency levels more stringent
than TSL 2 for low-voltage dry-type distribution transformers in part
because of risks associated with limitations in the available supply
and
[[Page 28242]]
quality of M4, M3, and amorphous steels.\6\ 78 FR 23421. If DOE
required more stringent levels of energy conservation in low-voltage
dry-type distribution transformers, manufacturers of the transformers
might have had to rely on M4, M3, or amorphous steels to meet those
conservation standards. Id.
---------------------------------------------------------------------------
\6\ These steels are among the most common grades used in
manufacture of distribution transformers. M3 and M4 are examples of
``conventional'' grain-oriented electrical steel, whereas amorphous
is the lowest-loss grade and a practical necessity to reach the very
highest efficiency levels.
---------------------------------------------------------------------------
DOE was concerned that if the next most stringent energy
conservation levels were adopted (TSL 3), then a significant number of
small manufacturers would be unable to acquire the M4, M3 or higher
quality steels in sufficient supply and quality to be able to compete.
Id. DOE indicated that this risk to small manufacturers outweighed the
benefits of adopting TSL 3 efficiency levels. Id. Additionally, DOE was
concerned that small manufacturers might not be able to procure
sufficient amounts of amorphous steel at competitive prices, if at all,
if energy conservation levels TSL 4, TSL 5, or TSL 6 were adopted. Id.
DOE indicated that the benefits of energy conservation levels TSL 4
through TSL 6 would be outweighed in part by this potential burden on
manufacturers. These determinations contributed to DOE's decision that
efficiency requirement levels higher than TSL 2 were not economically
justified. 78 FR 23419-23421.
II. Request for Information and Comments
In the following sections, DOE has identified a variety of issues
on which it seeks input to aid in the development of the technical and
economic analyses regarding whether amended standards for distribution
transformers may be warranted. Additionally, DOE welcomes comments on
other issues relevant to the conduct of this rulemaking that may not
specifically be identified in this document. In particular, DOE notes
that under Executive Order 13771, ``Reducing Regulation and Controlling
Regulatory Costs,'' Executive Branch agencies such as DOE are directed
to manage the costs associated with the imposition of expenditures
required to comply with Federal regulations. See 82 FR 9339 (Feb. 3,
2017). Consistent with that Executive Order, DOE encourages the public
to provide input on measures DOE could take to lower the cost of its
energy conservation standards rulemakings, recordkeeping and reporting
requirements, and compliance and certification requirements applicable
to distribution transformers while remaining consistent with the
requirements of EPCA.
A. Equipment Covered by This Process
This RFI covers equipment that meets the definitions of
distribution transformers, as codified at 10 CFR 431.192. The
definitions for distribution transformers were most recently amended in
an energy conservation standards final rule. 78 FR 23433. The current
definition for a distribution transformer codified in 10 CFR 431.192 is
the following:
Distribution transformer means a transformer that--
(1) Has an input voltage of 34.5 kV or less;
(2) Has an output voltage of 600 V or less;
(3) Is rated for operation at a frequency of 60 Hz; and
(4) Has a capacity of 10 kVA to 2500 kVA for liquid-immersed units
and 15 kVA to 2500 kVA for dry-type units; but
(5) The term ``distribution transformer'' does not include a
transformer that is an--
(i) Autotransformer; (ii) Drive (isolation) transformer; (iii)
Grounding transformer; (iv) Machine-tool (control) transformer; (v)
Nonventilated transformer; (vi) Rectifier transformer; (vii) Regulating
transformer; (viii) Sealed transformer; (ix) Special-impedance
transformer; (x) Testing transformer; (xi) Transformer with tap range
of 20 percent or more; (xii) Uninterruptible power supply transformer;
or (xiii) Welding transformer.
DOE notes that the excluded equipment listed above is specifically
excluded from energy conservation standards under EPCA at 42 U.S.C.
6291(35)(B)(ii)). Definitions for these terms are at 10 CFR 431.192 as
follows:
Autotransformer means a transformer that:
(1) Has one physical winding that consists of a series winding part
and a common winding part;
(2) Has no isolation between its primary and secondary circuits;
and
(3) During step-down operation, has a primary voltage that is equal
to the total of the series and common winding voltages, and a secondary
voltage that is equal to the common winding voltage.
Drive (isolation) transformer means a transformer that:
(1) Isolates an electric motor from the line;
(2) Accommodates the added loads of drive-created harmonics; and
(3) Is designed to withstand the additional mechanical stresses
resulting from an alternating current adjustable frequency motor drive
or a direct current motor drive.
Grounding transformer means a three-phase transformer intended
primarily to provide a neutral point for system-grounding purposes,
either by means of:
(1) A grounded wye primary winding and a delta secondary winding;
or
(2) A transformer with its primary winding in a zig-zag winding
arrangement, and with no secondary winding.
Liquid-immersed distribution transformer means a distribution
transformer in which the core and coil assembly is immersed in an
insulating liquid.
Machine-tool (control) transformer means a transformer that is
equipped with a fuse or other over-current protection device, and is
generally used for the operation of a solenoid, contactor, relay,
portable tool, or localized lighting
Medium-voltage dry-type 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 34.5 kV.
Mining distribution transformer means a medium-voltage dry-type
distribution transformer that is built only for installation in an
underground mine or surface mine, inside equipment for use in an
underground mine or surface mine, on-board equipment for use in an
underground mine or surface mine, or for equipment used for digging,
drilling, or tunneling underground or above ground, and that has a
nameplate which identifies the transformer as being for this use only.
Nonventilated transformer means a transformer constructed so as to
prevent external air circulation through the coils of the transformer
while operating at zero gauge pressure.
Rectifier transformer means a transformer that operates at the
fundamental frequency of an alternating-current system and that is
designed to have one or more output windings connected to a rectifier.
Regulating transformer means a transformer that varies the voltage,
the phase angle, or both voltage and phase angle, of an output circuit
and compensates for fluctuation of load and input voltage, phase angle
or both voltage and phase angle.
Sealed transformer means a transformer designed to remain
hermetically sealed under specified conditions of temperature and
pressure.
Special-impedance transformer means any transformer built to
operate at an impedance outside of the normal
[[Page 28243]]
impedance range for that transformer's kVA rating. The normal impedance
range for each kVA rating for liquid-immersed and dry-type transformers
is shown in Table II.1 and Table II.2 of this document, respectively.
Table II.1--Normal Impedance Ranges for Liquid-Immersed Distribution Transformers
----------------------------------------------------------------------------------------------------------------
Single-phase transformers Three-phase transformers
----------------------------------------------------------------------------------------------------------------
kVA Impedance (%) kVA Impedance (%)
----------------------------------------------------------------------------------------------------------------
10.............................................................. 1.0-4.5 15 1.0-4.5
15.............................................................. 1.0-4.5 30 1.0-4.5
25.............................................................. 1.0-4.5 45 1.0-4.5
37.5............................................................ 1.0-4.5 75 1.0-5.0
50.............................................................. 1.5-4.5 112.5 1.2-6.0
75.............................................................. 1.5-4.5 150 1.2-6.0
100............................................................. 1.5-4.5 225 1.2-6.0
167............................................................. 1.5-4.5 300 1.2-6.0
250............................................................. 1.5-6.0 500 1.5-7.0
333............................................................. 1.5-6.0 750 5.0-7.5
500............................................................. 1.5-7.0 1,000 5.0-7.5
667............................................................. 5.0-7.5 1,500 5.0-7.5
833............................................................. 5.0-7.5 2,000 5.0-7.5
.............. 2,500 5.0-7.5
----------------------------------------------------------------------------------------------------------------
Table II.2--Normal Impedance Ranges for Dry-Type Distribution Transformers
----------------------------------------------------------------------------------------------------------------
Single-phase transformers Three-phase transformers
----------------------------------------------------------------------------------------------------------------
kVA Impedance (%) kVA Impedance (%)
----------------------------------------------------------------------------------------------------------------
15.............................................................. 1.5-6.0 15 1.5-6.0
25.............................................................. 1.5-6.0 30 1.5-6.0
37.5............................................................ 1.5-6.0 45 1.5-6.0
50.............................................................. 1.5-6.0 75 1.5-6.0
75.............................................................. 2.0-7.0 112.5 1.5-6.0
100............................................................. 2.0-7.0 150 1.5-6.0
167............................................................. 2.5-8.0 225 3.0-7.0
250............................................................. 3.5-8.0 300 3.0-7.0
333............................................................. 3.5-8.0 500 4.5-8.0
500............................................................. 3.5-8.0 750 5.0-8.0
667............................................................. 5.0-8.0 1,000 5.0-8.0
833............................................................. 5.0-8.0 1,500 5.0-8.0
.............. 2,000 5.0-8.0
.............. 2,500 5.0-8.0
----------------------------------------------------------------------------------------------------------------
Testing transformer means a transformer used in a circuit to
produce a specific voltage or current for the purpose of testing
electrical equipment.
Transformer means a device consisting of 2 or more coils of
insulated wire that transfers alternating current by electromagnetic
induction from 1 coil to another to change the original voltage or
current value.
Transformer with tap range of 20 percent or more means a
transformer with multiple voltage taps, the highest of which equals at
least 20 percent more than the lowest, computed based on the sum of the
deviations of the voltages of these taps from the transformer's nominal
voltage.
Uninterruptible power supply transformer means a transformer that
is used within an uninterruptible power system, which in turn supplies
power to loads that are sensitive to power failure, power sags, over
voltage, switching transients, line noise, and other power quality
factors.
Welding transformer means a transformer designed for use in arc
welding equipment or resistance welding equipment.
Issue A.1: DOE requests comment on whether the definitions for
distribution transformers require any revisions--and if so, how those
definitions should be revised. In particular, DOE requests feedback
regarding how closely the kVA and voltage limits mirror those of
equipment generally considered to serve in a power distribution
capacity. DOE also requests feedback on whether the sub-category
definitions currently in place are appropriate or whether further
modifications are needed. If these sub-category definitions need
modifying, DOE seeks specific input on how to define these terms.
Issue A.2: DOE requests comment on whether additional equipment
definitions are necessary to close any potential gaps in coverage
between equipment types. DOE also seeks input on whether such products
currently exist in the market or whether they are being planned for
introduction. DOE also requests comment on opportunities to combine
equipment classes that could reduce regulatory burden.
B. Market and Technology Assessment
The market and technology assessment that DOE routinely conducts
when analyzing the impacts of a potential new or amended energy
conservation standard provides information about the distribution
transformers industry that will be used in DOE's analysis throughout
the rulemaking process. DOE uses qualitative and quantitative
information to characterize the structure of the industry and market.
DOE identifies manufacturers, estimates market shares
[[Page 28244]]
and trends, addresses regulatory and non-regulatory initiatives
intended to improve energy efficiency or reduce energy consumption, and
explores the potential for efficiency improvements in the design and
manufacturing of distribution transformers. DOE also reviews product
literature, industry publications, and company websites. Additionally,
DOE considers conducting interviews with manufacturers to improve its
assessment of the market and available technologies for distribution
transformers.
1. Equipment Classes
When evaluating and establishing energy conservation standards, DOE
may divide covered equipment into equipment classes by the type of
energy used, or by capacity or other performance-related features that
justify a different standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(q)) In
making a determination whether capacity or another performance-related
feature justifies a different standard, DOE must consider such factors
as the utility of the feature to the consumer and other factors DOE
deems appropriate. (Id.)
There are currently eleven equipment classes for distribution
transformers, one of which (mining transformers) is not presently
subject to energy conservation standards. 10 CFR 431.196. Ten of the
eleven equipment classes are determined according to the following
characteristics: (1) Type of transformer insulation: Liquid-immersed or
dry-type, (2) Number of phases: Single or three, (3) Voltage class: Low
or medium (for dry-type only), and (4) Basic impulse insulation level
(BIL) (for MVDT only). The eleventh equipment class is for mining
transformers, which is a reserved equipment class but is not currently
subject to energy conservation standards. 10 CFR 431.196(d). Table II.3
of this document lists the current 11 equipment classes for
distribution transformers.
Table II.3--Equipment Classes for Distribution Transformers
----------------------------------------------------------------------------------------------------------------
EC Insulation Voltage Phase BIL rating kVA range
----------------------------------------------------------------------------------------------------------------
1.......... Liquid-immersed... Medium............ Single............ ................... 10-833 kVA.
2.......... Liquid-immersed... Medium............ Three............. ................... 15-2500 kVA.
3.......... Dry-type.......... Low............... Single............ ................... 15-333 kVA.
4.......... Dry-type.......... Low............... Three............. ................... 15-1000 kVA.
5.......... Dry-type.......... Medium............ Single............ 20-45kV............ 15-833 kVA.
6.......... Dry-type.......... Medium............ Three............. 20-45kV............ 15-2500 kVA.
7.......... Dry-type.......... Medium............ Single............ 46-95kV............ 15-833 kVA.
8.......... Dry-type.......... Medium............ Three............. 46-95kV............ 15-2500 kVA.
9.......... Dry-type.......... Medium............ Single............ >=96kV............. 75-833 kVA.
10......... Dry-type.......... Medium............ Three............. >=96kV............. 225-2500 kVA.
----------------------------------------------------------------------------------------------------
11......... Mining Distribution Transformers
----------------------------------------------------------------------------------------------------------------
In the April 2013 standards rule, DOE added a definition for mining
distribution transformers. 78 FR 23353-23354; 10 CFR 431.192. In
deciding not to set standards for mining distribution transformers, DOE
explained that mining transformers are subject to several constraints
that are not usually concerns for transformers used in general power
distribution. Specifically because space is critical in mines, an
underground mining transformer may be at a considerable disadvantage in
meeting an efficiency standard; these transformers must supply power at
several output voltages simultaneously; and mining transformers in
general perform a role that may differ from general power distribution
in many regards, including lifetime, loading, and often the need to
supply power at several voltages simultaneously. 78 FR 23353. DOE
stated that it may consider establishing energy conservation standards
for mining distribution transformers at a later date. 78 FR 23354.
Specifically, DOE stated that it may set standards if it believes that
these transformers are being purchased as a way to circumvent energy
conservation standards for distribution transformers. Id.
Issue B.1: DOE requests information on the sale and use of mining
transformers, including information about the applications for which
mining transformers are currently being used, manufacturers of mining
transformers, sales data identifying end-users, and information about
the selling price. DOE requests comment on whether the features of
mining transformers specified in the regulatory definition limit its
use to mining applications, or whether they can be repurposed for
general, above-ground service. DOE also requests data characterizing
the relative performance abilities of mining transformers. In addition,
if use of mining transformers is observed in applications other than
underground, DOE requests comments on whether there are any technical
aspects of mining transformers that can be identified to improve DOE's
definition of mining transformers.
In the April 2013 standards rule, DOE also received several
comments regarding potential new equipment class setting factors, in
addition to those used to establish the equipment classes identified in
Table II.3 of this document. 78 FR 23354-23359. Specifically, Table
II.4 provides the potential equipment class setting factors (categories
of transformers) that were identified. These potential class setting
factors could, if warranted, be used to further subdivide the
distribution transformers currently subject to standards, as well as
any additional distribution transformers potentially considered in a
future standards rulemaking. In the April 2013 standards rule, DOE
determined that these categories of transformers did not warrant
separate equipment classes, and accordingly, these transformers are
subject to the existing equipment classes shown in Table II.3 of this
document. DOE stated that it may consider establishing separate
equipment classes for the same in the future.
[[Page 28245]]
Table II.4--Potential Class Setting Factors for Distribution
Transformers
------------------------------------------------------------------------
Transformer category Description
------------------------------------------------------------------------
Step-up transformers.............. Transformers that increase voltage
from primary to secondary (more
secondary winding turns than
primary winding turns).
Pole-mounted transformers......... Transformers that are mounted above-
ground on poles.
Pad-mounted transformers.......... Transformers that are ground
mounted, specifically in a locked
steel cabinet mounted on a concrete
pad.
Network transformers *............ Transformers that operate within a
grid configuration and connect end
loads to multiple distribution
transformers simultaneously; often
used for redundancy and in densely
populated areas.
Vault-based transformers *........ Transformers that have features
unique to operation in a vault,
which is a fully-enclosed chamber
dedicated to housing the
transformer and is not easily
expandable.
Submersible transformers *........ Transformers that are able to
maintain indefinite rated operation
while submerged.
Transformers with multi-voltage Transformers that are able to be
capacity. reconfigured to accommodate
different primary and secondary
voltages, in addition to those that
can provide multiple voltages
simultaneously.
------------------------------------------------------------------------
* There may be considerable overlap between ``network,'' ``vault-
based,'' and ``submersible'' transformers, i.e., transformers with one
of the three properties may often have another. However, they are
separated here as they are not always linked and carry different
features and limitations.
Issue B.2: DOE requests comment on whether equipment subject to
present and potential future energy conservation standards should be
classified based on the factors presented in Table II.4 in any
potential future energy conservation standards rulemaking. If so, DOE
requests information on (i) which new equipment class(es) should be
included, and, (ii) how the performance-related features of equipment
in the class affect both consumer utility and efficiency. Additionally,
DOE requests comment on whether DOE should consider additional
equipment classes not identified in the table, information on the
performance-related features that provide unique consumer utility, and
data detailing the corresponding impacts on energy use that would
justify separate equipment classes.
Lastly, DOE also received comments from several stakeholders
indicating BIL affects efficiency in liquid-immersed distribution
transformers. 78 FR 23357-23358. Specifically, some commenters
suggested setting separate energy conservation standards based on BIL
for liquid-immersed distribution transformers. 78 FR 23357. Commenters
stated that standards by BIL rating will help differentiate
transformers that require more insulation and that are less efficient.
Id. Several other stakeholders supported the concept of exploring how
BIL affects efficiency but felt that it was not a significant enough
issue to delay publication of the rule. Id. Specifically, commenters
stated that the efficiency levels under consideration do not warrant
separating by BIL and pointed out that the efficiency impacts of varied
BIL were smaller in liquid-immersed than in dry-type transformers. Id.
While DOE did not include equipment class by BIL rating in the April
2013 standards rule because DOE did not find a strong technological
need for such separation at the efficiency levels under consideration,
DOE did state that it may consider establishing equipment classes by
BIL rating when considering future standards. 78 FR 23357-23358
Issue B.3: DOE requests comment on whether separate equipment
classes by BIL rating should be considered for liquid-immersed
distribution transformers. If so, please describe why and provide
information to characterize the effect of BIL on performance.
2. Technology Assessment
In analyzing the feasibility of potential new or amended energy
conservation standards, DOE uses information about existing and past
technology options and prototype designs to help identify technologies
that manufacturers could use to meet and/or exceed a given set of
energy conservation standards under consideration. In consultation with
interested parties, DOE intends to develop a list of technologies to
consider in its analysis. That analysis will likely include a number of
the technology options DOE previously considered during its most recent
rulemaking for distribution transformers.
In the April 2013 standards rule, DOE identified several technology
options and designs considered under that rulemaking.\7\ 78 FR 23359.
Increases in transformer efficiency are based on reduction of
transformer losses. There are two main types of losses in transformers:
No-load (core) losses and load (winding) losses. Measures taken to
reduce one type of loss typically increase the other type of loss. Some
examples of technology options to improve efficiency include: (1)
Higher-grade electrical core steels, (2) different conductor types and
materials, and (3) adjustments to core and coil configurations. A
summary of the technology options from the April 2013 standards rule
are presented in Table II.5 and Table II.6 of this document.
---------------------------------------------------------------------------
\7\ A more detailed discussion can be found in section 3.8 of
chapter 3, and chapter 4 of the April 2013 standards rule Technical
Support Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
Table II.5--Previously Considered Technology Options and Impacts of Increasing Transformer Efficiency for the
April 2013 Standards Rule
----------------------------------------------------------------------------------------------------------------
No-load losses Load losses Cost impact
----------------------------------------------------------------------------------------------------------------
To decrease no-load losses:
Use lower-loss core materials... Lower................... No change *............ Higher.
Decrease flux density by:
Increasing core cross- Lower................... Higher................. Higher.
sectional area (CSA).
Decreasing volts per turn... Lower................... Higher................. Higher.
Decrease flux path length by Lower................... Higher................. Lower.
decreasing conductor CSA.
Use 120[deg] symmetry in three- Lower................... No change.............. TBD.
phase cores **.
[[Page 28246]]
To decrease load losses:
Use lower-loss conductor No change............... Lower.................. Higher.
material.
Decrease current density by Higher.................. Lower.................. Higher.
increasing conductor CSA.
Decrease current path length by:
Decreasing core CSA......... Higher.................. Lower.................. Lower.
Increasing volts per turn... Higher.................. Lower.................. Lower.
----------------------------------------------------------------------------------------------------------------
* Amorphous core materials would result in higher load losses because flux density drops, requiring a larger
core volume.
** Sometimes referred to as a ``hexa-transformer'' design.
Table II.6--Other Previously Considered Technology Options in the April
2013 Standards Rule *
------------------------------------------------------------------------
-------------------------------------------------------------------------
Silver as a Conductor Material
High-Temperature Superconductors
Amorphous Core Material in Stacked Core Configuration
Carbon Composite Materials for Heat Removal
High-Temperature Insulating Material
Solid-State (Power Electronics) Technology
Nanotechnology Composites
------------------------------------------------------------------------
* Note: These technology options were not listed as such in the April
2013 standards rule because they were removed in the screening
analysis.
Issue B.4: DOE requests comment on the technologies listed in Table
II.5 and Table II.6 of this document regarding their applicability to
the current market, costs, and how these technologies may improve
efficiency of distribution transformers as measured according to the
DOE test procedure. DOE also seeks information on how these
technologies and related costs may have changed since they were
considered in the April 2013 standards rule. Specifically, DOE seeks
information as to whether steel grades and fabrication techniques have
been updated or improved since the April 2013 standards rule.
In addition, DOE has also identified several potential new
technology options that could improve efficiency of distribution
transformers. These new technology options are presented in Table II.7
of this document.
Table II.7--Potential New Technology Options for Distribution
Transformers
------------------------------------------------------------------------
-------------------------------------------------------------------------
Core Deactivation
Symmetric Core
Less-flammable insulating liquids
------------------------------------------------------------------------
Core deactivation technology uses a system of smaller transformers
to replace a single, larger transformer. For example, three 25 kVA
transformers operating in parallel could replace a single 75 kVA
transformer. A control unit constantly monitors the unit's power
output, and based on the known efficiency of each combination of
transformers for any given loading, the control unit operates the
optimal number of cores. In the April 2013 standards rule, DOE stated
that although core deactivation technology has some potential to save
energy over a real-world loading cycle, those savings might not be
represented in the current DOE test procedure, and that each of the
constituent transformers must comply with the applicable energy
conservation standard.\8\ 78 FR 23360.
---------------------------------------------------------------------------
\8\ A more detailed discussion can be found on page 3-28 of
chapter 3 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Symmetric core technology describes a design strategy wherein each
leg of the transformer is connected to the other two. It uses a
continuously wound core with 120-degree radial symmetry, resulting in a
triangularly shaped core when viewed from above. Because of zero-
sequence fluxes \9\ associated with wye-wye connected transformers,
symmetric core designs may be best suited to delta-delta or delta-wye
connections. In the April 2013 standards rule, DOE lacked the data
necessary to perform a thorough engineering analysis of symmetric core
designs, and therefore did not consider symmetric core technology for
the rulemaking.\10\ 78 FR 23360-23362.
---------------------------------------------------------------------------
\9\ ``Zero-sequence'' is a term used to describe a state in
which flux among a transformer's three electrical phases is
occurring simultaneously, rather than at the usual staggered
intervals. In this state, damage or failure can be mitigated if both
connections (i.e., input and output) are of the delta arrangement.
\10\ A more detailed discussion can be found on page 3-29 of
chapter 3 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Less-flammable insulating liquid technology is specific to liquid-
immersed distribution transformers and refers to filling these
transformers with an insulating fluid of higher flash point \11\ than
that of traditional mineral oil. This technology can benefit certain
applications in which a fire would be especially costly. In the April
2013 standards rule, DOE considered whether this technology might be
disproportionally affected by standards set in the liquid-immersed
equipment class and concluded that was not likely to be the case.
Specifically, DOE received some feedback suggesting that less-flammable
insulating liquids might be capable of higher efficiencies than mineral
oil units because their higher temperature tolerances may allow the
unit to be downsized and operated at higher temperatures than those
using mineral oils.\12\ 78 FR 23355.
---------------------------------------------------------------------------
\11\ The flash point is the lowest temperature at which vapors
above the fluid will ignite, given an ignition source.
\12\ A more detailed discussion can be found on page 3-24 of
chapter 3, and page 5-22 of chapter 5 of the April 2013 standards
rule Technical Support Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue B.5: DOE requests comment on the technologies listed in Table
II.7 of this document. Specifically, DOE seeks information about
technological maturity, market adoption, costs, and any related
concerns (e.g., impacts on consumer utility). DOE further requests
comment on its definition of core deactivation technology as a system
of distribution transformers. DOE also seeks comment on other
technology options that it should consider for inclusion in its
analysis.
Issue B.6: DOE seeks comment on whether there have been sufficient
technological or market changes since the most recent standards update
that may justify a new rulemaking to consider more stringent standards.
Specifically, DOE seeks data and information that could enable the
agency to determine whether DOE should propose a ``no new standard''
determination because a more stringent standard: 1. would not result in
a significant savings of energy; 2. is not technologically feasible; 3.
is not
[[Page 28247]]
economically justified; or 4. any combination of the foregoing.
3. Electrical Steel Market Assessment
a. Amorphous Steel--Producers
In its preliminary review of the amorphous steel market, DOE
identified at least six companies with amorphous steel mills either
already in production or at some stage of development. While DOE is
aware of only one producer of amorphous ribbon in the United States;
three companies in China have each recently increased their production
capacity; one corporation has built a plant in South Korea and plans to
enter the amorphous steel market; and an additional corporation
produces at least some amorphous steel. DOE has found no indication
that either of the two domestic electrical steel production companies
have any plans to enter the amorphous steel market.
Issue B.7: DOE seeks comments, data, and information regarding
current producers of amorphous steel and any barriers to entry by other
producers or factors that could lead existing producers to exit the
amorphous steel market. Comments may include, but are not limited to,
identifying producers of amorphous steel not already identified in
DOE's preliminary review of the amorphous steel market, and anticipated
future trends in producers entering and exiting this market.
b. Amorphous Steel--Production Capacity
In its preliminary analysis of the steel market, DOE identified the
quantity of amorphous steel produced by some of the companies currently
in production. The global annual production capacity of amorphous
ribbon of the one established producer is at least 100,000 tons of
which 45,000 tons are located in the United States. Additionally, the
three mills in China have recently increased their collective annual
production capacity to 90,000 tons of amorphous steel and had plans, as
of September 2016, to add an additional 40,000 to 50,000 tons in 2016.
Issue B.8: DOE seeks comments, data, and information quantifying
and characterizing the current market capacity for amorphous steel, and
potential changes in the production capacity as compared to current
production capacity.
c. Amorphous Steel--Quality
In its preliminary analysis of the steel market, DOE also
identified improvements in the quality of amorphous steel produced by
some of the steel makers. In particular, the brittleness, stacking
factor, and flux density of the amorphous steel produced in China have
been improved since the April 2013 standards rule was issued.
Additionally, the three companies in China can all now produce
amorphous steel in the same widths as available on the U.S. market.
Issue B.9: DOE seeks comments, data, and information about historic
trends in the quality of amorphous steel, the quality of the amorphous
steel currently in production as it pertains to use in manufacturing
energy-efficient distribution transformers. Additionally, DOE seeks
comments, data, and information about any planned changes in the
quality of amorphous steel and potential future trends in the quality
of amorphous steel.
d. Non-Amorphous Steel--Market Conditions
In its preliminary review of the core steel market, DOE identified
an increase in the use by transformer manufacturers of high
permeability steels rather than M3 steel, which has resulted, in part,
due to efficiency standards in the United States, the European Union,
and India as well as China's efforts to improve the efficiency of its
electricity grid.
Issue B.10: DOE seeks comments, data, and information about changes
in the market conditions for low-voltage, dry-type distribution
transformers that could inform DOE's decision to reevaluate the current
energy conservation standards including any changes in the availability
and quality of M4, M3, or other steels used in the manufacturing of
efficient low-voltage dry-type distribution transformers.
C. Screening Analysis
The purpose of the screening analysis is to evaluate the
technologies that improve equipment efficiency to determine which
technologies will be eliminated from further consideration and which
will be passed to the engineering analysis for further consideration.
DOE determines whether to eliminate certain technology options from
further consideration based on the following criteria defined at 10 CFR
part 430, subpart C, appendix A, 4(a)(4) and 5(b) as follows:
(1) Technological feasibility. Technologies that are not
incorporated in commercial products or in working prototypes will not
be considered further.
(2) Practicability to manufacture, install, and service. If it is
determined that mass production of a technology in commercial products
and reliable installation and servicing of the technology could not be
achieved on the scale necessary to serve the relevant market at the
time of the compliance date of the standard, then that technology will
not be considered further.
(3) Impacts on equipment utility or equipment availability. If a
technology is determined to have significant adverse impact on the
utility of the equipment to significant subgroups of consumers, or
result in the unavailability of any covered equipment type with
performance characteristics (including reliability), features, sizes,
capacities, and volumes that are substantially the same as equipment
generally available in the United States at the time, it will not be
considered further.
(4) Adverse impacts on health or safety. If it is determined that a
technology will have significant adverse impacts on health or safety,
it will not be considered further.
Technology options identified in the technology assessment are
evaluated against these criteria using DOE analyses and inputs from
interested parties (e.g., manufacturers, trade organizations, and
energy efficiency advocates). Technologies that pass through the
screening analysis are referred to as ``design options'' in the
engineering analysis. Technology options that fail to meet one or more
of the four criteria are eliminated from consideration.
Additionally, DOE notes that the four screening criteria do not
directly address the propriety status of technology options. DOE only
considers potential efficiency levels achieved through the use of
proprietary designs in the engineering analysis if they are not part of
a unique pathway to achieve that efficiency level (i.e., if there are
other non-proprietary technologies capable of achieving the same
efficiency level).
Table II.8 summarizes the technology options that DOE screened out
in the April 2013 standards rule, and the applicable screening
criteria.
[[Page 28248]]
Table II.8--Previously Screened Out Technology Options From the April
2013 Standards Rule \13\
------------------------------------------------------------------------
Technology option excluded Eliminating 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 Technological feasibility;
Configuration. Practicability to manufacture,
install, and service.
Carbon Composite Materials for Heat Technological feasibility.
Removal.
High-Temperature Insulating Material... Technological feasibility.
Solid-State (Power Electronics) Technological feasibility;
Technology. Practicability to manufacture,
install, and service.
Nanotechnology Composites.............. Technological feasibility.
------------------------------------------------------------------------
Issue C.1: DOE requests feedback on how the four screening criteria
would relate to the possible technology options available for
distribution transformers listed in section II.A of this document, and
any other technologies not identified in this document.
---------------------------------------------------------------------------
\13\ A more detailed discussion can be found in chapter 4 of the
April 2013 standards rule Technical Support Document, available
from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue C.2: DOE seeks information on whether the technology options
listed in section II.B.2 of this document would continue to be
eliminated from further consideration based on the four screening
criteria.
D. Engineering Analysis
The engineering analysis estimates the cost-efficiency relationship
of equipment at different levels of increased energy efficiency
(``efficiency levels''). This relationship serves as the basis for the
cost-benefit calculations for consumers, manufacturers, and the Nation.
In determining the cost-efficiency relationship, DOE estimates the
increase in manufacturer production cost (``MPC'') associated with
increasing the efficiency of equipment above the baseline, up to the
maximum technologically feasible (``max-tech'') efficiency level for
each equipment class.
DOE historically has used the following three methodologies to
generate incremental manufacturing costs and establish efficiency
levels (``ELs'') for analysis: (1) The design-option approach, which
provides the incremental costs of adding to a baseline model design
options that will improve its efficiency; (2) the efficiency-level
approach, which provides the relative costs of achieving increases in
energy efficiency levels, without regard to the particular design
options used to achieve such increases; and (3) the cost-assessment (or
reverse engineering) approach, which provides ``bottom-up''
manufacturing cost assessments for achieving various levels of
increased efficiency, based on detailed cost data for parts and
material, labor, shipping/packaging, and investment for models that
operate at particular efficiency levels.
1. General Methodology
In the April 2013, standards rule, DOE based its engineering
analysis on a design-option approach, in which design software was used
to assess the cost-efficiency relationship between various design
option combinations.\14\ 78 FR 23364. DOE analyzed eleven equipment
classes, as discussed in section II.B.1. DOE then further classified
distribution transformers by their kVA rating, within each equipment
class. These kVA ratings are essentially size categories, indicating
the power handling capacity of the transformers. For the rulemaking,
there was a total of 100 kVA ratings across all equipment classes.
---------------------------------------------------------------------------
\14\ A more detailed discussion can be found on page 5-2 of
chapter 5 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
DOE recognized that it would be impractical to conduct a detailed
engineering analysis on each kVA rating, and therefore developed an
approach that simplified the analysis while retaining reasonable levels
of accuracy. DOE found that many of the units share similar designs and
construction methods and, on that basis, DOE simplified the analysis by
creating engineering design lines (DLs), which group kVA ratings based
on similar principles of design and construction. The DLs subdivide the
equipment classes to improve the accuracy of the engineering analysis.
These DLs differentiate the transformers by insulation type (liquid
immersed or dry-type), number of phases (single or three), and primary
insulation levels for medium-voltage dry-type distribution transformers
(three different BIL levels).\15\ 78 FR 23364.
---------------------------------------------------------------------------
\15\ A more detailed discussion of the structure of the
engineering analysis can be found on page 5-1 of chapter 5 of the
April 2013 standards rule Technical Support Document, available
from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
After developing its DLs, DOE then selected one representative unit
from each DL for study, greatly reducing the number of units for direct
analysis. These representative units are listed in Table II.9 of this
document.
Table II.9--Engineering Design Lines and Representative Units
----------------------------------------------------------------------------------------------------------------
Type of distribution
EC[thinsp]* DL transformer kVA range Representative unit
----------------------------------------------------------------------------------------------------------------
1...................... 1 Liquid-immersed, single- 10-167 50 kVA, 65 [deg]C, single-phase,
phase, rectangular tank. 60Hz, 14400V primary, 240/120V
secondary, rectangular tank,
95kV BIL.
1...................... 2 Liquid-immersed, single- 10-167 25 kVA, 65 [deg]C, single-phase,
phase, round tank. 60Hz, 14400V primary, 120/240V
secondary, round tank, 125 kV
BIL.
1...................... 3 Liquid-immersed, single- 250-833 500 kVA, 65 [deg]C, single-
phase. phase, 60Hz, 14400V primary,
277V secondary, 150kV BIL.
2...................... 4 Liquid-immersed, three- 15-500 150 kVA, 65 [deg]C, three-phase,
phase. 60Hz, 12470Y/7200V primary,
208Y/120V secondary, 95kV BIL.
[[Page 28249]]
2...................... 5 Liquid-immersed, three- 750-2500 1500 kVA, 65 [deg]C, three-
phase. phase, 60Hz, 24940GrdY/14400V
primary, 480Y/277V secondary,
125 kV BIL.
3...................... 6 Dry-type, low-voltage, 15-333 25 kVA, 150 [deg]C, single-
single-phase. phase, 60Hz, 480V primary, 120/
240V secondary, 10kV BIL.
4...................... 7 Dry-type, low-voltage, 15-150 75 kVA, 150 [deg]C, three-phase,
three-phase. 60Hz, 480V primary, 208Y/120V
secondary, 10kV BIL.
4...................... 8 Dry-type, low-voltage, 225-1000 300 kVA, 150 [deg]C, three-
three-phase. phase, 60Hz, 480V Delta
primary, 208Y/120V secondary,
10kV BIL.
6...................... 9 Dry-type, medium-voltage, 15-500 300 kVA, 150 [deg]C, three-
three-phase, 20-45kV BIL. phase, 60Hz, 4160V Delta
primary, 480Y/277V secondary,
45kV BIL.
6...................... 10 Dry-type, medium-voltage, 750-2500 1500 kVA, 150 [deg]C, three-
three-phase, 20-45kV BIL. phase, 60Hz, 4160V primary,
480Y/277V secondary, 45kV BIL.
8...................... 11 Dry-type, medium-voltage, 15-500 300 kVA, 150 [deg]C, three-
three-phase, 46-95kV BIL. phase, 60Hz, 12470V primary,
480Y/277V secondary, 95kV BIL.
8...................... 12 Dry-type, medium-voltage, 750-2500 1500 kVA, 150 [deg]C, three-
three-phase, 46-95kV BIL. phase, 60Hz, 12470V primary,
480Y/277V secondary, 95kV BIL.
10..................... 13A Dry-type, medium-voltage, 75-833 300 kVA, 150 [deg]C, three-
three-phase, 96-150kV BIL. phase, 60Hz, 24940V primary,
480Y/277V secondary, 125kV BIL.
10..................... 13B Dry-type, medium-voltage, 225-2500 2000 kVA, 150 [deg]C, three-
three-phase, 96-150kV BIL. phase, 60Hz, 24940V primary,
480Y/277V secondary, 125kV BIL.
----------------------------------------------------------------------------------------------------------------
* There is not a 1:1 correspondence of equipment classes and design lines.
Issue D.1: For each representative unit, DOE generated hundreds of
unique designs by contracting with Optimized Program Services, Inc.
(OPS), a software company specializing in transformer design. The OPS
software used three primary inputs that it received from DOE: (1) A
design option combination, which included core steel grade, primary and
secondary conductor material, and core configuration; (2) a loss
valuation combination; and (3) material prices. For each representative
unit, DOE examined anywhere from 8 to 16 design option combinations and
for each design option combination, the OPS software generated 518
designs based on unique loss valuation combinations. These loss
valuation combinations are known in industry as A and B evaluation
combinations, and represent a commercial consumer's present value of
future losses in a transformer core and winding, respectively. For each
design option combination and A and B combination, the OPS software
generated an optimized transformer design based on the material prices
that were also part of the inputs. Consequently, DOE obtained thousands
of transformer designs for each representative unit. The performance of
these designs ranged in efficiency from a baseline level, equivalent to
the current distribution transformer energy conservation standards, to
a theoretical max-tech efficiency level. DOE requests comment on
whether a future rulemaking, if initiated, should include a greater
breadth or depth of engineering design simulations.
After generating each design, DOE used the outputs of the OPS
software to help create a manufacturer selling price (MSP). The
material cost corresponding to the outputs of the OPS software, along
with labor estimates, were marked up for scrap factors, factory
overhead, shipping, and non-production costs to generate a MSP for each
design. Thus, DOE obtained a cost versus efficiency relationship for
each representative unit. Finally, after DOE generated the MSPs versus
efficiency relationship for each representative unit, it extrapolated
the results to the other, unanalyzed, kVA ratings within that same
engineering design line.
Issue D.2: DOE requests comment on whether its method of performing
the engineering analysis should be maintained in any future rulemaking
analysis, if conducted.
Issue D.3: DOE requests comment on whether there are additional
methods to establish the relationship between transformer selling price
and efficiency. For example, DOE seeks comment on whether bid responses
for publicly owned utilities would provide a representative design and
pricing data to develop a more accurate cost-efficiency relationship
and whether such data exists in sufficient volume at efficiency levels
above the Federal minimum.
2. Price Inputs to Analysis
As described at the beginning of this section, the main outputs of
the engineering analysis are cost-efficiency relationships that
describe the estimated increases in MPC associated with higher-
efficiency equipment for each analyzed equipment class. For
distribution transformers, one of the inputs to the MPC is the
materials costs. The primary material costs in distribution
transformers come from electrical steel used for the core and the
aluminum or copper conductor used for the primary and secondary
winding. DOE attempted to account for the frequent fluctuation in price
of these commodities by examining prices over multiple years.
For the April 2013 standards rule, DOE used its estimates of both
2010-year and 2011-year prices as reference cases for results. To
construct materials price estimates, DOE spoke with manufacturers,
suppliers, and industry experts to determine the prices paid for each
raw material used in a distribution transformer. DOE developed an
average materials price for the year based on the price a medium-to-
large manufacturer would pay.\16\ 78 FR 23367.
---------------------------------------------------------------------------
\16\ A more detailed discussion can be found on page 5-40 of
chapter 5 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
The prices of aluminum and copper conductor, in particular,
correlated strongly to the price of the underlying commodities, which
are tracked in various public indices (e.g. the LME). As a result,
extrapolation of 2010- and 2011-year prices using the index prices of a
future time period may yield sufficiently accurate conductor prices for
that time period. Extrapolation of past conductor prices may be more
accurate than direct use of the index prices, as the latter do not
include
[[Page 28250]]
transformer industry-specific costs such as drawing into wire and
shipping.
Issue D.4: DOE requests comment on whether metals price indices,
such as those published by the London Metal Exchange (LME) and CME
Group (e.g., the COMEX), may be reliably used to extrapolate 2010 and
2011 prices to the present. DOE requests comment on whether there are
any other price indices that should be considered. DOE also requests
comment on the impact of tariffs on the price of raw materials used
manufacturing distribution transformers.
a. Liquid-Immersed Transformers
Table II.10 and Table II.11 respectively contain material price
data for liquid-immersed distribution transformers relied upon in the
April 2013 standards rule.\17\
---------------------------------------------------------------------------
\17\ Materials prices for liquid-immersed distribution
transformers were not presented in the final rule Federal Register
notice, but can be found on page 5-42 of chapter 5 of the April 2013
standards rule Technical Support Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
Table II.10--Typical Manufacturer's Material Prices for Liquid-Immersed
Design Lines From the April 2013 Standards Rule
------------------------------------------------------------------------
Item and description 2010 price 2011 price
------------------------------------------------------------------------
M6 core steel........................... 1.33 1.04
M5 core steel........................... 1.38 1.10
M4 core steel........................... 1.45 1.20
M3 core steel........................... 1.88 1.30
M3 Lite Carlite core steel.............. 1.95 1.95
M2 core steel........................... 2.00 1.40
M2 Lite Carlite core steel.............. 2.10 2.10
ZDMH (mechanically-scribed core steel).. 2.05 1.90
SA1 (amorphous)--finished core, volume 2.38 2.20
production.............................
Copper wire, formvar, round #10-20...... 4.87 4.87
Copper wire, enameled, round #7-10...... 4.84 4.84
Copper wire, enameled, rectangular sizes 4.97 4.97
Aluminum wire, formvar, round #9-17..... 3.07 3.07
Aluminum wire, formvar, round #7-10..... 2.57 2.57
Copper strip, thickness range 0.02-0.045 4.97 4.97
Copper strip, thickness range 0.030- 4.97 4.97
0.060..................................
Aluminum strip, thickness range 0.02- 2.08 2.08
0.045..................................
Aluminum strip, thickness range 0.045- 2.08 2.08
0.080..................................
Kraft insulating paper with diamond 1.52 1.52
adhesive...............................
Mineral oil............................. 3.35 3.35
Tank Steel.............................. 0.38 0.38
------------------------------------------------------------------------
Table II.11--Summary Table of Fixed Material Costs for Liquid-Immersed Units From the April 2013 Standards Rule
----------------------------------------------------------------------------------------------------------------
Item and description DL1 DL2 DL3 DL4 DL5
----------------------------------------------------------------------------------------------------------------
High voltage bushings........... $28 $6 $6 $21 $60
Low voltage bushings............ $30 $8 $60 $24 $160
Core clamp, nameplate, and misc. 41.65 19.15 50.65 75.65 105.65
hardware.......................
Transformer tank average cost *. ~143 ~73 ~629 ~389 ~1,016
----------------------------------------------------------------------------------------------------------------
Issue D.5: DOE requests comment on the prices of materials and
labor used to construct liquid-immersed distribution transformers,
including all grades of electrical steel, that are presented in section
II.D.2.a. Such data may include data both in absolute terms and
expressed relative to the 2010 and 2011 estimates from the April 2013
standards rule.
b. Dry-Type Transformers
Table II.12 and Table II.13 respectively contain material cost data
for dry-type distribution transformers relied upon in the April 2013
standards rule.\18\
---------------------------------------------------------------------------
\18\ Materials prices for dry-type transformers were not
presented in the final rule Federal Register notice, but can be
found on page 5-44 of chapter 5 of the April 2013 standards rule
Technical Support Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
Table II.12--Manufacturer's Material Prices for Dry-Type Design Lines
From the April 2013 Standards Rule
------------------------------------------------------------------------
Item and description 2010 price 2011 price
------------------------------------------------------------------------
M36 core steel (26 gauge)............... 0.60 0.66
M19 core steel (26 gauge)............... 0.83 0.91
M12 core steel.......................... 0.95 0.78
M6 core steel........................... 1.33 1.04
M5 core steel........................... 1.38 1.10
M4 core steel........................... 1.45 1.20
M3 core steel........................... 1.88 1.30
[[Page 28251]]
M2 core steel........................... 2.00 1.40
H-0 DR core steel (laser-scribed)....... 2.06 1.70
SA1 (amorphous)--finished core, volume 2.38 2.20
production.............................
Copper wire, rectangular 0.1 x 0.2, 4.52 4.52
Nomex wrapped..........................
Aluminum wire, rectangular 0.1 x 0.2, 2.97 2.97
Nomex wrapped..........................
Copper strip, thickness range 0.02-0.045 4.97 4.97
Aluminum strip, thickness range 0.02- 2.08 2.08
0.045..................................
Nomex insulation (per pound)............ 24.50 24.50
Cequin insulation (per pound)........... 5.53 5.53
Impregnation (per gallon)............... 22.55 22.55
Winding Combs (per pound)............... 12.34 12.34
Enclosure Steel (per pound)............. 0.38 0.38
------------------------------------------------------------------------
Table II.13--Summary Table of Fixed Material Costs for Dry-Type Units From the April 2013 Standards Rule
--------------------------------------------------------------------------------------------------------------------------------------------------------
Item DL $6 DL $7 DL $8 DL $9 DL $10 DL $11 DL $12 DL $13A DL $13B
--------------------------------------------------------------------------------------------------------------------------------------------------------
LV and HV terminals (set)............................ 4 n/a n/a 75 120 100 135 115 150
HV terminal board(s)................................. n/a 27 27 27 27 27 27 27 27
LV bus[dash]bar...................................... n/a 10.50 22.50 80 140 80 192 100 270
Core/coil mounting frame............................. 9.25 19 36 36 120 42 125 50 175
Additional Bracing................................... n/a n/a n/a n/a ~230 n/a ~270 n/a ~330
Nameplate............................................ 0.65 0.65 0.65 0.65 0.65 0.65 0.65 0.65 0.65
Dog-bone duct spacer (ft.)........................... 0.24 0.32 0.42 0.42 0.52 0.42 0.56 0.42 0.60
Winding combs (lb.).................................. n/a n/a n/a n/a n/a 10.00 10.00 10.00 10.00
Misc. hardware....................................... 4.50 7 12 25 42 32 54 36 60
Enclosure (12, 14 gauge)............................. ~50 ~90 ~100 ~135 ~400 ~200 ~450 ~200 ~450
--------------------------------------------------------------------------------------------------------------------------------------------------------
Issue D.6: DOE requests comment on the prices of materials used to
construct dry-type distribution transformers, including all grades of
electrical steel, that are presented in section II.D.2.b. Such data may
include data both in absolute terms and expressed relative to the 2010
and 2011 estimates from the April 2013 standards rule.
c. Labor Markups
Table II.14 contains labor cost data for both liquid-immersed and
dry-type manufacturers relied upon in the April 2013 standards
rule.\19\
---------------------------------------------------------------------------
\19\ Labor markups were not presented in the final rule Federal
Register notice, but can be found on page 5-49 of chapter 5 of the
April 2013 standards rule Technical Support Document, available
from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
Table II.14--Labor Markups for Liquid-Immersed and Dry-Type
Manufacturers
------------------------------------------------------------------------
Markup Rate per hour
Item description percentage ($)
------------------------------------------------------------------------
Labor cost per hour *................... .............. 16.80
Indirect Production **.................. 33 22.35
Overhead ***............................ 30 29.05
Fringe [dagger]......................... 24 36.03
Assembly Labor Up[dash]time 43 51.52
[dagger][dagger].......................
Fully-Burdened Cost of Labor............ 25 64.40
------------------------------------------------------------------------
* Cost per hour is from U.S. Census Bureau, 2007 Economic Census--
Detailed Statistics, published October 2009. Data for NAICS code
3353111 ``Power and distribution transformers, except parts''
Production workers' hours and wages.
** Indirect production labor (e.g., production managers, quality
control) as a percent of direct labor on a cost basis. Navigant
Consulting, Inc. (NCI) estimate.
*** Overhead includes commissions, dismissal pay, bonuses, vacation,
sick leave, and social security contributions. NCI estimate.
[dagger] Fringe includes pension contributions, group insurance premiums
worker's compensation. Source: U.S. Census Bureau, 2007 Economic
Census--Detailed Statistics, published October 2009. Data for NAICS
code 3353111 ``Power and distribution transformers, except parts''
Total fringe benefits as a percent of total compensation for all
employees (not just production workers).
[dagger][dagger] Assembly labor up-time is a factor applied to account
for the time that workers are not assembling units and/or reworking
unsatisfactory units. The markup of 43 percent represents a 70 percent
utilization (multiplying by 100/70). NCI estimate.
Issue D.7: DOE requests comment on the prices of labor used to
construct distribution transformers that are presented in section
II.D.2.c. of this document. Such data may include data both in absolute
terms and expressed relative to estimates from the April 2013 standards
rule.
3. Load Loss Scaling
Currently, DOE energy conservation standards apply only at a single
per-unit load (PUL) value for a given distribution
[[Page 28252]]
transformer equipment class (e.g., 50% for liquid-immersed). 10 CFR
431.196. However, distribution transformers exhibit varying efficiency
with varying PUL.
Distribution transformer loss is commonly separated into ``load''
and ``no-load'' components. The former is often approximated as a
quadratic function of PUL, i.e., load losses grow in proportion to the
square of PUL. 78 FR 23372. Transformers in service may deviate from
this simplified assumption for a variety of reasons (e.g., temperature
rise) and DOE is requesting comment on the nature and magnitude of that
deviation.
Issue D.8: DOE requests comment on how load losses vary as a
function of per-unit load. Specifically, DOE seeks mathematical
characterizations of load losses, expressed as a function of PUL. DOE
is especially interested in learning about formulas that may be more
accurate than the widely used quadratic approximation, and explanations
of the bases of those formulas.
E. Distribution Channels
In generating end-user price inputs for the life-cycle cost
(``LCC'') analysis and national impact analysis (``NIA''), DOE must
identify distribution channels (i.e., how the products are distributed
from the manufacturer to the consumer), and estimate relative sales
volumes through each channel Markups depend on the distribution
channels for the different equipment classes and consumer types, for
both new construction and replacement equipment. In the April 2013
standards rule, DOE characterized these distribution channels as
described in the following sections and shown in Table II.15 of this
document.
1. Liquid-Immersed Distribution Transformers
DOE assumed for liquid-immersed distribution transformers sold to
investor-owned utilities (IOUs) that 82 percent of sales were direct
from the manufacturer to a utility consumer through a national account,
and the remaining 18 percent of sales were through a transformer
distributor.\20\ 78 FR 23371. For liquid-immersed distribution
transformers sold to publicly owned utilities, DOE assumed that all
sales were through a transformer distributor.\21\
---------------------------------------------------------------------------
\20\ A more detailed discussion can be found on page 6-7 of
chapter 6 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
\21\ Distribution channels are discussed in detail on page 6-1
of chapter 6 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
2. Dry-Type Distribution Transformers
In the April 2013 rule, DOE assumed dry-type distribution
transformers were installed by an electrical contractor. An electrical
contractor usually purchases the distribution transformer from a
distributor, and in this case, DOE assumed it was appropriate to
include a contractor markup.
Table II.15--Distribution Channels for Distribution Transformers
----------------------------------------------------------------------------------------------------------------
Market share
Type Consumer (%) Distribution channel
----------------------------------------------------------------------------------------------------------------
Liquid-immersed....................... Investor-owned utility... 82 Manufacturer (National
Account) [rarr] Consumer.
18 Manufacturer [rarr]
Distributor [rarr] Consumer.
Publicly-owned utility... 100 Manufacturer [rarr]
Distributor [rarr] Consumer.
LVDT.................................. All...................... 100 Manufacturer [rarr]
Distributor [rarr]
Electrical contractor [rarr]
Consumer.
MVDT.................................. All...................... 100 Manufacturer [rarr]
Distributor [rarr]
Electrical contractor [rarr]
Consumer.
----------------------------------------------------------------------------------------------------------------
Issue E.1: DOE seeks input from stakeholders on whether the
distribution channels described above continue to accurately describe
the distribution chain for distribution transformers and are sufficient
to describe the distribution market.
Issue E.2: DOE seeks input on the percentage of equipment
distributed through the different distribution channels, and whether
the share of equipment through each channel varies based on equipment
capacity, or number of phases, or other equipment characteristics.
F. Energy Use Analysis
As part of the rulemaking process, DOE conducts an energy use
analysis to identify how products are used by consumers, and thereby
determine the energy savings potential of energy efficiency
improvements. The energy-use analysis produces energy use estimates and
end-use load shapes for distribution transformers. The energy use
estimates enable evaluation of energy savings from the operation of
distribution transformers at various efficiency levels, while the end-
use load characterization allows evaluation of the impact on monthly
and peak demand for electricity.
The energy used by distribution transformers is characterized by
two types of losses. The first are no-load losses, which are also known
as core losses. No-load losses are roughly constant and exist whenever
the transformer is energized (i.e., connected to live power lines). The
second are load losses, which are also known as resistance or I\2\R
losses. Load losses generally vary with the square of the PUL being
served by the transformer.
DOE is considering using the same methodology for its energy-use
analysis as it did in the April 2013 standards rule, where it assumed
the following: (1) Application of distribution transformers vary
significantly by transformer type (liquid-immersed or dry-type) and
ownership; (2) electric utilities own approximately 95 percent of
liquid-immersed transformers; and (3) commercial/industrial (C&I)
entities use mainly dry-type distribution transformers. To account for
the differences in transformer application, in the April 2013 standards
rule, DOE performed two separate end-use load analyses to evaluate
distribution transformer efficiency, as described in the following
sections.\22\ 78 FR 23372.
---------------------------------------------------------------------------
\22\ The energy-use analysis is discussed in detail in Chapter 7
and Appendix 7A of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
1. Hourly Load Analysis
The hourly load analysis for liquid-immersed distribution
transformers used two types of information related to electric
utilities. The first was drawn from the Energy Information
Administration's (EIA's) Form 861
[[Page 28253]]
database.\23\ Form 861 provides, through its Form 2, the annual sales
in megawatt-hours for each utility to the residential, commercial, and
industrial sectors. Form 861's Form 4 lists all the utilities that own
electricity distribution equipment, and the county in which that
equipment is located. Based on those data, DOE created a consumer
sample of utilities that own transformers and assigned a sample weight
to each based on the electricity sales of that utility.
---------------------------------------------------------------------------
\23\ U.S. Department of Energy-Energy Information
Administration. Form EIA-861: Annual Electric Power Industry
Database. (2008). at https://www.eia.doe.gov/cneaf/electricity/page/eia861.html.
---------------------------------------------------------------------------
The second type of utility information used is hourly system loads
and prices. DOE developed regional system loads and prices for the set
of regions defined in the EIA National Energy Modeling System (NEMS)
Electricity Market Module (EMM).\24\ The regions represent both
national reliability regions and, where they exist, integrated
wholesale electricity markets. Each region in turn comprises a number
of electric utility control area operators (CAOs), some of which may
also be utility companies. DOE obtained hourly load and system lambda
data (for regions without wholesale markets) or day-ahead market price
data (for market regions) from the Federal Energy Regulatory Commission
(FERC) Form 714 database.\25\ DOE aggregated the hourly data to produce
regional time series for the EMM regions.\26\
---------------------------------------------------------------------------
\24\ Energy Information Administration--Office of Integrated
Analysis and Forecasting. The National Energy Modeling System
(NEMS): An Overview. (U.S. Department of Energy, 2009). at https://www.eia.doe.gov/oiaf/aeo/overview/.
\25\ U.S. Department of Energy-Federal Energy Regulatory
Commission. Form No. 714--Annual Electric Control and Planning Area
Report. (U.S. Department of Energy-Federal Energy Regulatory
Commission, 2008). at https://www.ferc.gov/docs-filing/forms/form-714/overview.asp.
\26\ The hourly load analysis is discussed in detail in Chapter
7 and Appendix 7A of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
From these data, DOE estimated the loads on individual liquid-
immersed distribution transformers for both residential and non-
residential utility consumers by creating hourly proxy transformer
loads. These resulted in the initial (first year) RMS load for liquid-
immersed transformers ranging from 34 and 40 percent for single- and
three-phase equipment, respectively. Additionally, as in the April 2013
standards rule, DOE is considering projecting the energy consumption
for distribution transformers into the future. This projection included
a 0.5 percent per-year load growth factor to account for utility growth
in the connected load on liquid-immersed distribution transformers, and
no-load growth for LVDT and MVDT transformers.\27\ 78 FR 23375.
---------------------------------------------------------------------------
\27\ A more detailed discussion can be found on page 8-25 of
chapter 8 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue F.1: DOE requests comment on whether it should use the hourly
load analysis for liquid-immersed distribution transformers relied upon
in April 2013 standards rule and what updates to the inputs should be
considered. Included in the type of information that DOE would find
useful are: (i) Sources of data and recommendations to support an
hourly load model; (ii) data on utility-owned distribution transformer
hourly loads for the liquid-immersed equipment classes under
consideration; (iii) field or simulated energy use data or other
relevant information that could assist in the development or
calibration for its hourly load analysis; (iv) data and information
supporting or refuting the assumption that larger capacity liquid-
immersed transformers are loaded to a higher degree than smaller
capacity liquid-immersed transformers, and; (v) any other data
commenters believe would be relevant.
Issue F.2: DOE requests comment on the appropriateness of its prior
assumption of future load growth. Examples of information requested
include, but are not limited to, sources of data or recommendation to
support to an annual load growth assumption, and information on whether
the growth of connected loads would vary with geography, transformer
type, capacity, or phase-count.
a. Utilities Serving Low Population Densities
DOE recognizes that in rural areas, the number of utility customers
per distribution transformer is likely to be significantly lower than
in urban or suburban areas, which in turn results in lower PULs. DOE is
considering using the same methodology that it used in the April 2013
standards rule, where the PUL was reduced by 10 percent for utilities
serving counties with less than 32 households per square mile.\28\
---------------------------------------------------------------------------
\28\ PUL estimates for utilities serving low population
densities were not presented in the final rule Federal Register
notice, but can be found on page 8-16 of chapter 8 of the April 2013
standards rule Technical Support Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue F.3: DOE seeks comment on the continued appropriateness of
the adjustment to the PUL for areas with low population density,
including information and data as to the PULs experienced by
transformers in-service in low population density areas.
2. Monthly Load Analysis
The consumer sample for the monthly load analysis used for LVDT and
MVDT distribution transformer owners was taken from the EIA's
Commercial Buildings Energy Consumption Survey (CBECS) databases.\29\
Survey data for the years 1992 and 1995 were used, as these are the
only years for which monthly consumer electricity consumption (kWh) and
peak demand (kW) are provided. To account for changes in the
distribution of building floor space by building type and size, the
weights defined in the 1992 and 1995 building samples were rescaled to
reflect the distribution in the 2012 CBECS survey. CBECS covers
primarily commercial buildings, but a significant fraction of
transformers are shipped to industrial building owners. To account for
this in the sample, data from the EIA's 2010 Manufacturing Energy
Consumption Survey (MECS) \30\ was used to estimate the amount of floor
space of buildings that might use the type of transformer covered by
the rulemaking. The statistical weights assigned to the building sample
were rescaled to reflect this additional floor space.
---------------------------------------------------------------------------
\29\ Commercial Building Energy Consumption and Expenditures
Survey (CBECS); 1992 and 1995; U.S. Department of Energy--Energy
Information Administration; https://www.eia.doe.gov/emeu/cbecs/microdat.html.
\30\ Manufacturing Energy Consumption Survey (MECS); 2006 U.S.
Department of Energy--Energy Information Administration; https://www.eia.gov/emeu/mecs/contents.html.
---------------------------------------------------------------------------
From these data, in the April 2013 standards rule, DOE estimated
that on average, the RMS PUL for LVDT transformers ranged from 20 and
25 percent for commercial and industrial consumers, respectively;\31\
and that, on average, the RMS PUL for MVDT transformers ranged from 32
and 38 percent for commercial and industrial consumers,
respectively.\32\
---------------------------------------------------------------------------
\31\ The result of DOE's transformer load analysis for LVDT
distribution transformers are contained in the Life-cycle Cost and
Payback Period spreadsheet tools for DLs 6 through 8 on the Forecast
Cells tab. (available at: https://www.regulations.gov/document?D=EERE-2011-BT-STD-0051-0085)
\32\ The result of DOE's transformer load analysis for MVDT
distribution transformers are contained in the Life-cycle Cost and
Payback Period spreadsheet tools for DL 9 through 13B on the
Forecast Cells tab. (available at: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0764)
---------------------------------------------------------------------------
Issue F.4: DOE requests comment on the methodology for determining
monthly loads for LVDT and MVDT
[[Page 28254]]
equipment classes relied upon in the April 2013 standards rule and
whether DOE should consider changes to the methodology.
Issue F.5: DOE requests comment on the appropriateness of the data
sources relied upon for determining monthly loads for LVDT and MVDT
equipment classes in the April 2013 standards rule and whether
additional sources should be considered. Comments may include field or
simulated energy use data or other relevant information that could
assist in the development or calibration for its monthly load analysis.
G. Life-Cycle Cost and Payback Period Analysis
The purpose of the LCC and PBP analyses is to evaluate the economic
impacts of potential energy conservation standards on individual
consumers. The effect of new or amended energy conservation standards
on consumers usually involves a reduction in operating cost and an
increase in purchase cost.
DOE intends to analyze the potential for variability by performing
the LCC and PBP calculations on a representative sample of individual
consumers. DOE plans to utilize the sample of buildings developed for
the energy use analysis and the corresponding simulation results.\33\
DOE plans to model uncertainty in many of the inputs to the LCC and PBP
analysis using Monte Carlo simulation and probability distributions. As
a result, the LCC and PBP results will be displayed as distributions of
impacts compared to the no-new-standards case (without amended
standards) conditions.
---------------------------------------------------------------------------
\33\ DOE plans to utilize the utility information from EIA-Form
851 and FERC No. 714, commercial, and manufacturing building types
defined in CEBCS and MECS databases.
---------------------------------------------------------------------------
Issue G.1: DOE requests comment on the overall methodology that it
intends to use to conduct the LCC and PBP analysis for distribution
transformers.
1. Base-Case Efficiency Distributions
To determine an appropriate base case against which to compare
various potential standard levels, in the April 2013 standards rule DOE
incorporated in the LCC calculations a purchase-decision model that
specifies which of the hundreds of designs from the engineering
database are likely to be selected by transformer purchasers to meet a
given efficiency level. The engineering analysis yielded a cost-
efficiency relationship in the form of MSPs, no-load losses, and load
losses for a wide range of realistic transformer designs. This set of
data provides the LCC model with a distribution of transformer design
choices.
If it determines that a rulemaking is necessary, DOE plans on using
the same approach as in the April 2013 standards rule that employs the
selection criteria known in the transformer industry as total owning
cost (TOC). The TOC method combines transformer first costs with the
consumer's cost of losses to produce a present value of losses over the
lifetime of a transformer. Consumers of distribution transformers,
especially in the utility sector, have long used the TOC method to
determine which transformers to purchase. DOE refers to those consumers
who employ the TOC method to determine which transformer to purchase in
the context of the LCC as ``evaluators''.
In the April 2013 standards rule, DOE assumed the following
fraction of consumers to be evaluators: 10 percent for liquid-immersed
transformers, and 2 percent for both LVDT and MVDT transformers. DOE
assumed the fraction of evaluators to select a transformer with the
best TOC for their cost of losses (this was usually of higher
efficiency than the baseline), while the remaining consumers, who were
not considered evaluators, selected new distribution transformers at
the baseline efficiency.\34\ 78 FR 23374.
---------------------------------------------------------------------------
\34\ The transformer selection approach is discussed in detail
in chapter 8 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue G.2: DOE seeks information on the fraction of consumers who
employ an evaluation methodology, such as the Total Owning Cost
methodology,35 36 that may lead to transformer purchases at
a cost greater than lowest-first-costs. Further, DOE seeks information
on whether this changes with the size of consumer (in terms of peak
demand), or by equipment class or equipment capacity.
---------------------------------------------------------------------------
\35\ IEEE, Loss Evaluation Guide for Power Transformers and
Reactors, 1992, DOI: 10.1109/IEEESTD.1992.114388.
\36\ United States Department Of Agriculture: Rural Utilities
Services, Guide for Economic Evaluation of Distribution
Transformers, August 2016, RUS Bulletin 1724D-107, See: https://www.rd.usda.gov/files/UEP_Bulletin_1724D-107.pdf.
---------------------------------------------------------------------------
Issue G.3: DOE seeks information on the fraction of consumers who
purchase LVDT transformers at efficiencies at, or greater than, those
specified under the NEMA Premium Efficiency Transformer Program.\37\
---------------------------------------------------------------------------
\37\ See: https://www.nema.org/Technical/Pages/NEMA-Premium-Efficiency-Transformers-Program.aspx
---------------------------------------------------------------------------
2. Installation Costs
The primary inputs for establishing the total installed cost are
the baseline consumer price, standard-level consumer price increases,
and installation costs. Baseline transformer prices and standard-level
transformer price increases will be determined by applying markups to
MSP estimates.
a. Impact of Increased Distribution Transformer Weight on Installation
Costs
Total installed costs for distribution transformers dependent
heavily on the weight of the equipment. DOE plans to derive the weight-
versus-capacity relationship for a typical distribution transformer
from the design data produced by the engineering analysis as it did in
the April 2013 standards rule. DOE estimated a scaling relationship
between transformer weight, and direct installation labor and equipment
costs from RSMeans for the electrical equipment categories: ``dry-type
transformer'', ``oil-filled transformer'', and ``transformer, liquid-
filled''.\38\
---------------------------------------------------------------------------
\38\ See page 6-2 of chapter 6 of the April 2013 standards rule
Technical Support Document for a more detailed discussion on
transformer installation costs, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue G.4: DOE seeks information and data on the installation cost
versus transformer weight relationship for the different types of
transformers and capacities under consideration.
b. Estimation of Pole Replacement Costs
In addition to including installation costs that scale with
transformer weight, DOE is considering including costs to account for
the rare occasion that a more efficient pole-mounted replacement
transformer may require the installation of a new, higher-grade,
utility pole to support any increase in weight due to increased
transformer efficiency.\39\ If it determines that a rulemaking is
necessary, DOE plans to use the same methodology it used in the April
2013 standards rule, where the pole-replacement cost function was
applied to those modelled design lines that included pole-mounted
distribution transformers.\40\ 78 FR 23374.
---------------------------------------------------------------------------
\39\ In the April 2013 standards rule DOE estimated an average
relative increase in transformer weight when compared to baseline
equipment to be between 14 percent and 4 percent for DL 2, and DL 3,
respectively. In absolute terms, the average weight increase was
between 48 lbs. and 120 lbs. for DL 2, and DL3, respectively. The
results of DOE's pole replacement analysis for pole-mounted liquid-
immersed distribution transformers are contained in the Life-cycle
Cost and Payback Period spreadsheet tools for DL 2 and DL 3 on the
Forecast Cells tab. (available at: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0767)
\40\ See page 6-2 of chapter 6 of the April 2013 standards rule
Technical Support Document for a more detailed discussion on
transformer installation costs, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
[[Page 28255]]
The degree of weight increase depends on how a transformer design
is modified to improve efficiency. For pole-mounted transformers
(represented by design lines 2 and 3 in the April 2013 standards rule),
the increased weight may lead to situations where the pole needs to be
upgraded to support the additional weight of the transformer, which in
turn, leads to an increase in the installation cost.
The methodology employed in the April 2013 standards rule
established the threshold change in weight of the transformer between
the no-new standards case and standard case level that would trigger
the need to upgrade the utility pole to support the new more efficient
transformer. DOE assumed that a pole change-out would only be necessary
if the weight increase was greater than 15 percent of the base case and
was also 150 pounds heavier than the weight of the base case unit for
a25 kVA unit. To determine the weight-change threshold for larger
capacity units (i.e., 500kVA), the 150-pound threshold was scaled using
the 0.75 scaling rule \41\ to 1,418 pounds. In some cases, utilities
have the option to reinforce pole or structures with guy wires instead
of outright pole replacement. Because of the general practice of over-
sizing of utility poles for safety reasons, and the availability of
other supporting options, DOE limited the total fraction of pole
replacements to 25 percent of the total population. 78 FR 23374-23375
---------------------------------------------------------------------------
\41\ The 0.75 Scaling Rule holds that for similarly designed
transformers, costs of construction and losses scale with the ratio
of their kVA ratings raised to the 0.75 power. See 78 FR 23369 for a
more detailed description of the 0.75 Scaling Rule.
---------------------------------------------------------------------------
Issue G.5: DOE seeks comment on its prior approach to accounting
for the need for pole replacement, including data on the rate of pole
change-out that is driven by the increased weight of more efficient
distribution transformers of the same capacity.
The cost of pole replacement typically involves the removal of the
old pole and its disposal, erection of the upgraded replacement pole,
and the transferring of all attached equipment and concessions. DOE
plans on using the labor and equipment cost estimates from the RSMeans,
to construct a distribution of possible costs paid by a utility when
performing a pole replacement for single pole, and multi-pole
(platform) replacements.
Issue G.6: DOE seeks comment on its understanding of utility pole
upgrades that result from an increase in transformer weight; the
continued appropriateness of this consideration, including but not
limited to information and data on the rate of pole change-out and on
the cost of pole replacement by transformer capacity.
Issue G.7: DOE seeks information on any other factors that would
impact transformer installations costs due to an increase in
transformer efficiency.
3. Electricity Prices
DOE plans to estimate electricity prices and costs to place a value
on transformer losses using the same methodologies it used in the April
2013 standards rule. One hourly methodology captured the nature of
regional hourly transformer loads, their correlation with the overall
utility system load, and their correlation with hourly electricity
costs and prices. The monthly methodology estimated the impacts of
transformer loads and resultant losses on monthly electricity usage,
demand, and electricity bills. DOE plans to use the hourly analysis for
liquid-immersed transformers, which are owned predominantly by
utilities that pay costs that vary by the hour, and the monthly
analysis for dry-type transformers, which typically are owned by
commercial and industrial establishments that receive monthly
electricity bills.\42\ 78 FR 73375-73377.
---------------------------------------------------------------------------
\42\ A more detailed discussion can be found on page 8-17 of
chapter 8 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
a. Hourly Electricity Costs
To evaluate the electricity costs associated with liquid-immersed
distribution transformers, DOE plans to use marginal electricity
prices. Marginal prices are those utilities pay for the last kilowatt-
hour of electricity produced and may be higher or lower than the
average price, depending on the relationships among capacity,
generation, transmission, and distribution costs. The general structure
of the hourly marginal cost methodology divides the costs of
electricity into capacity components and energy cost components. For
each component, the economic value for both no-load losses and load
losses is estimated. The capacity components include generation and
transmission capacity; it also includes a reserve margin for ensuring
system reliability, with factors that account for system losses. Energy
cost components include a marginal cost of supply that varies by the
hour.
DOE plans on using a marginal costs methodology for the set of EMM
regions. To calculate the hourly price of electricity, DOE plans on
using the day-ahead market clearing price for regions having wholesale
electricity markets, and system lambda values for all other regions.
System lambda values, which are roughly equal to the operating cost of
the next unit in line for dispatch, are filed by control area operators
under FERC Form 714. DOE plans on using the most recent data available
for both market prices and system lambdas.
Issue G.8: DOE seeks comment on its approach for developing hourly
electricity prices, as well as additional sources of relevant data.
b. Monthly Electricity Costs
To evaluate the electricity costs associated with LVDT and MVDT
distribution transformers, DOE plans to derive nationally
representative distributions of annual electricity prices for different
consumer categories (industrial, commercial, and residential) from the
most recent data available in the EIA Form 861, ``Annual Electric Power
Industry Report,'' as well as data from the Edison Electric
Institute.\43\
---------------------------------------------------------------------------
\43\ Edison Electric Institute. Typical Bills and Average Rates
Report. Washington, DC, October 2016.
---------------------------------------------------------------------------
Issue G.9: DOE seeks comment on its approach for developing monthly
electricity prices as well as additional sources of relevant data.
4. Future Electricity Prices
DOE plans to use projections of national average energy prices for
commercial and industrial consumers to estimate future energy prices.
DOE will use the most recent available edition of AEO as the default
source of projections for future energy prices.
Issue G.10: DOE seeks comment on its consideration of future
electricity prices as well as additional relevant sources for
projecting future electricity prices.
H. Shipments
DOE develops shipments forecasts of distribution transformers to
calculate the national impacts of potential amended energy conservation
standards on energy consumption, net present value (``NPV''), and
future manufacturer cash flows. DOE shipments projections are based on
available historical data broken out by equipment class and capacity.
Current sales estimates allow for a more accurate model that captures
recent trends in the market.
In the April 2013 standards rule, DOE used sales estimates for the
entire market for distribution transformers for years 2001 and 2009,
disaggregated by transformer type (liquid-immersed or
[[Page 28256]]
dry-type) and kVA rating.44 45 DOE projected these shipments
to future years by assuming that annual transformer shipments growth is
equal to growth in electricity consumption as given by AEO 2012, and
then continuing this rate from 2030 to 2045. DOE assumed that the
market share of transformers for each type, and at each capacity, to be
constant throughout the analysis period. If DOE initiates an energy
conservation standards rulemaking, DOE will consider using a similar
approach.\46\
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\44\ Hopkinson, P. & Puri, J. Distribution Transformer Market
Shipment Estimates for 2001. (HVOLT Consultants Inc.: Washington DC,
2003).
\45\ Hopkinson, P. & Puri, J. Distribution Transformer Market
Shipment Estimates for 2009. (HVOLT Consultants Inc.: Washington DC,
2010).
\46\ The market shares for distribution transformers were not
presented in the final rule Federal Register notice, but can be
found on page 9-11 of chapter 9 of the April 2013 standards rule
Technical Support Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
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Issue H.1: DOE seeks comment on its approach to estimating current
shipments and future sales. Such information may include, but need not
be limited to: (i) Data and information on current and historical
shipments and market shares of distribution transformers categories
discussed in this notice; (ii) data and information on the distribution
of shipments (in units) of distribution transformers discussed in this
notice by rated capacity, type, BIL, and installation application
(pole-mounted, surface pad-mounted, subsurface pad-mounted); and (iii)
data and information on how the distribution of shipments of
distribution transformers discussed in this notice has changed over
time by rated capacity, type, BIL, and installation application (pole-
mounted, surface pad-mounted, subsurface pad-mounted).
Issue H.2: DOE requests comment on the approach it intends on using
to develop the shipments model and shipments forecasts for distribution
transformers under consideration for potential standards.
1. Equipment Lifetimes
The equipment lifetime is the age at which the equipment is retired
from service. DOE plans on using the same approach that it used in the
April 2013 standards rule, which was based on a report by Oak Ridge
National Laboratory.\47\ It estimated that the average life of a
distribution transformer is 32 years. This lifetime estimate includes a
constant failure rate of 0.5 percent/year due to lightning and other
random failures unrelated to transformer age, and an additional
corrosive failure rate of 0.5 percent/year starting at year 15. 78 FR
23377
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\47\ Barnes. Determination Analysis of Energy Conservation
Standards for Distribution Transformers. ORNL-6847. 1996.
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Issue H.3: DOE seeks comments on its approach for estimating
equipment lifetimes.
2. Purchase Price Elasticity and Refurbished Transformers
DOE recognizes that increase in transformer prices due to changes
in standards may cause changes in purchases of new transformers. Due to
the essential nature of the utility provided by a distribution
transformer, the option to forego purchase, or substitute with other
equipment, is very limited. However, because the general trend of
utility transformer purchases is determined by increases in generation,
utilities could conceivably exercise some discretion in how much
transformer stock to buy--the amount of ``over-capacity'' to purchase
and hold as reserve stock, and may draw on these reserves instead of
purchasing new equipment. In addition, some utilities may choose to
refurbish failed transformers and return them to service, rather than
purchase a new transformer if the price of the latter increases
significantly.
In the April 2013 standards rule, DOE estimated the purchase price
elasticity at -0.04 for liquid-immersed transformers, and -0.02 for all
dry-type transformers. To capture the negative impact on the national
energy saving estimates of replacement refurbished liquid-immersed
transformers, DOE assumed that the operational need for a fraction of
forgone purchases due to an increase in price would be met with less
efficient refurbished equipment. DOE assumed that 20 percent of these
foregone purchases would be met by refurbished transformers; and that
refurbished transformers would have shorter average lifetimes at 20
years, and an efficiency of 70 percent, of baseline transformers of the
same capacity and equipment class.\48\ 78 FR 23379.
---------------------------------------------------------------------------
\48\ A more detailed discussion can be found on page 9-14 of
chapter 9 of the April 2013 standards rule Technical Support
Document, available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue H.4: DOE requests comment on the purchase price elasticity
values of -0.04 and -0.02 for liquid-immersed and dry-type
transformers, respectively.
Issue H.5: DOE requests comments on the assumptions regarding
consumer response to amended standards made in the April 2013 standards
rule, including but not limited to information and data on the fraction
and efficiency characteristics of transformers that are refurbished and
are returned to service, and whether the decision to use refurbished
equipment would vary with equipment capacity, installation application,
or other circumstances.
The following tables of the types of data requested for 2018
shipments in can be found in Table II.16 and Table II.17 of this
document. Interested parties are also encouraged to provide additional
shipment data as may be relevant.
Table II.16--Summary Table of Single-Phase Distribution Transformers Shipments-Related Data Requests
[Units Shipped, 2018]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Liquid-immersed, medium- Dry-type, medium- Dry-type, medium- Dry-type, medium-
kVA range voltage Dry-type, low- voltage voltage, 20-45 kV BIL voltage, 46-95 kV BIL voltage, >=96 kV BIL
--------------------------------------------------------------------------------------------------------------------------------------------------------
10........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
15........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
25........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
37.5......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 28257]]
50........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
75........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
100.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
167.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
250.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
333.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
500.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
667.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
833.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
* BIL = basic impulse insulation level.
Table II.17--Summary Table of Three-Phase Distribution Transformers Shipments-Related Data Requests
[Units Shipped, 2018]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Liquid-immersed, medium- Dry-type, medium- Dry-type, medium- Dry-type, medium-
kVA range voltage Dry-type, low-voltage voltage, 20-45 kV BIL voltage, 46-95 kV BIL voltage, >=96 kV BIL
--------------------------------------------------------------------------------------------------------------------------------------------------------
15........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
30........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
45........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
75........................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
112.5........................ ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
150.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
225.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
300.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
500.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
750.......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
1000......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
1500......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
2000......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
2500......................... ....................... ....................... ....................... ...................... ......................
--------------------------------------------------------------------------------------------------------------------------------------------------------
* BIL = basic impulse insulation level.
If disaggregated fractions of annual sales are not available at the
equipment type level, DOE requests more aggregated fractions of annual
sales at the category level.
Issue H.6: If available, DOE requests the same information in Table
II.16 and Table II.17 of this document for the previous five years
(2013 through 2017).
I. Manufacturer Impact Analysis
The purpose of the manufacturer impact analysis (``MIA'') is to
estimate the financial impact of amended energy conservation standards
on manufacturers of distribution transformers, and to evaluate the
potential impact of such standards on direct employment and
manufacturing capacity. The MIA includes both quantitative and
qualitative aspects. The quantitative part of the MIA primarily relies
on the Government Regulatory Impact Model (``GRIM''), an industry cash-
flow model adapted for the equipment in this analysis, with the key
output of industry net present value (``INPV''). The qualitative part
of the
[[Page 28258]]
MIA addresses the potential impacts of energy conservation standards on
manufacturing capacity and industry competition, as well as factors
such as equipment characteristics, impacts on particular subgroups of
firms, and important market and equipment trends.
To account for manufacturers' non-production costs and profit
margin, DOE applies a non-production cost multiplier (the manufacturer
markup) to the MPC. The resulting MSP is the price at which
manufacturers sell their distribution transformers to their first
commercial consumer along the distribution chain. For the April 2013
standards rule, DOE used a manufacturer markup of 1.25 for all
distribution transformer equipment classes: liquid-immersed, LVDT and
MVDT.\49\
---------------------------------------------------------------------------
\49\ Manufacturer markups were not presented in the final rule
Federal Register notice, but can be found on pages 12-18 through 12-
23 of the April 2013 standards rule Technical Support Document,
available from: https://www.regulations.gov/document?D=EERE-2010-BT-STD-0048-0760.
---------------------------------------------------------------------------
Issue I.1: DOE requests feedback on whether a manufacturer markup
of 1.25 is appropriate for all distribution transformers.
As part of the MIA, DOE intends to analyze impacts of amended
energy conservation standards on subgroups of manufacturers of covered
equipment, including small business manufacturers. DOE uses the Small
Business Administration's (``SBA'') small business size standards to
determine whether manufacturers qualify as small businesses, which are
listed by the applicable North American Industry Classification System
(``NAICS'') code.\50\ Manufacturing of consumer distribution
transformers is classified under NAICS 335311, ``Power, Distribution,
and Specialty Transformer Manufacturing,'' and the SBA sets a threshold
of 750 employees or less for a domestic entity to be considered as a
small business. This employee threshold includes all employees in a
business' parent company and any other subsidiaries.
---------------------------------------------------------------------------
\50\ Available online at https://www.sba.gov/document/support-table-size-standards.
---------------------------------------------------------------------------
One aspect of assessing manufacturer burden involves examining the
cumulative impact of multiple DOE standards and the equipment-specific
regulatory actions of other Federal agencies that affect the
manufacturers of a covered product or equipment. While any one
regulation may not impose a significant burden on manufacturers, the
combined effects of several existing or impending regulations may have
serious consequences for some manufacturers, groups of manufacturers,
or an entire industry. Assessing the impact of a single regulation may
overlook this cumulative regulatory burden. In addition to energy
conservation standards, other regulations can significantly affect
manufacturers' financial operations. Multiple regulations affecting the
same manufacturer can strain profits and lead companies to abandon
product lines or markets with lower expected future returns than
competing products. For these reasons, DOE conducts an analysis of
cumulative regulatory burden as part of its rulemakings pertaining to
appliance efficiency.
Issue I.2: To the extent feasible, DOE seeks the names and contact
information of any domestic or foreign-based manufacturers that
distribute distribution transformers in the United States.
Issue I.3: DOE requests feedback on the degree to which small
businesses perform core manufacturing techniques themselves, such as
assembly and mitering, versus choosing to outsource, and the
corresponding effect on capital investments required to achieve greater
efficiencies. DOE requests specific comment on relative changes in
these practices relative to before the April 2013 standards rule.
Issue I.4: DOE identified small businesses as a subgroup of
manufacturers that could be disproportionally impacted by amended
energy conservation standards. DOE requests the names and contact
information of small business manufacturers, as defined by the SBA's
size threshold, of distribution transformers that distribute products
in the United States. In addition, DOE requests comment on any other
manufacturer subgroups that could be disproportionally impacted by
amended energy conservation standards. DOE requests feedback on any
potential approaches that could be considered to address impacts on
manufacturers, including small businesses.
Issue I.5: DOE requests information regarding the cumulative
regulatory burden impacts on manufacturers of distribution transformers
associated with (1) other DOE standards applying to different products
that these manufacturers may also make and (2) equipment-specific
regulatory actions of other Federal agencies. DOE also requests comment
on its methodology for computing cumulative regulatory burden and
whether there are any flexibilities it can consider that would reduce
this burden while remaining consistent with the requirements of EPCA.
J. Other Energy Conservation Standards Topics
1. Market Failures
In the field of economics, a market failure is a situation in which
the market outcome does not maximize societal welfare. Such an outcome
would result in unrealized potential welfare. DOE welcomes comment on
any aspect of market failures, especially those in the context of
amended energy conservation standards for distribution transformers.
2. Emerging Smart Technology Market
DOE recently published an RFI on the emerging smart technology
appliance and equipment market. 83 FR 46886 (Sept. 17, 2018). In that
RFI, DOE sought information to better understand market trends and
issues in the emerging market for appliances and commercial equipment
that incorporate smart technology. DOE's intent in issuing the RFI was
to ensure that DOE did not inadvertently impede such innovation in
fulfilling its statutory obligations in setting efficiency standards
for covered products and equipment. DOE seeks comments, data and
information on the issues presented in the RFI as they may be
applicable to distribution transformers.
3. Other
In addition to the issues identified earlier in this document, DOE
welcomes comment on any other aspect of energy conservation standards
for distribution transformers not already addressed by the specific
areas identified in this document.
III. Submission of Comments
DOE invites all interested parties to submit in writing by August
2, 2019, comments and information on matters addressed in this document
and on other matters relevant to DOE's consideration of amended energy
conservations standards for distribution transformers. After the close
of the comment period, DOE will review the public comments received and
may begin collecting data and conducting the analyses discussed in this
RFI.
Submitting comments via https://www.regulations.gov. The https://www.regulations.gov web page requires you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies Office staff only. Your contact information will
not be publicly viewable except for your first and last names,
organization name (if any), and submitter representative name (if any).
If your comment is not processed
[[Page 28259]]
properly because of technical difficulties, DOE will use this
information to contact you. If DOE cannot read your comment due to
technical difficulties and cannot contact you for clarification, DOE
may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment or in any documents attached to your comment.
Any information that you do not want to be publicly viewable should not
be included in your comment, nor in any document attached to your
comment. Persons viewing comments will see only first and last names,
organization names, correspondence containing comments, and any
documents submitted with the comments.
Do not submit to https://www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (``CBI'')). Comments submitted
through https://www.regulations.gov cannot be claimed as CBI. Comments
received through the website will waive any CBI claims for the
information submitted. For information on submitting CBI, see the
Confidential Business Information section.
DOE processes submissions made through https://www.regulations.gov
before posting. Normally, comments will be posted within a few days of
being submitted. However, if large volumes of comments are being
processed simultaneously, your comment may not be viewable for up to
several weeks. Please keep the comment tracking number that
www.regulations.gov provides after you have successfully uploaded your
comment.
Submitting comments via email, hand delivery/courier, or postal
mail. Comments and documents submitted via email, hand delivery/
courier, or postal mail also will be posted to https://www.regulations.gov. If you do not want your personal contact
information to be publicly viewable, do not include it in your comment
or any accompanying documents. Instead, provide your contact
information on a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via postal mail
or hand delivery/courier, please provide all items on a CD, if
feasible. It is not necessary to submit printed copies. No
telefacsimiles (faxes) will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, written in English and free of any defects or viruses.
Documents should not contain special characters or any form of
encryption and, if possible, they should carry the electronic signature
of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. According to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
one copy of the document marked confidential including all the
information believed to be confidential, and one copy of the document
marked ``non-confidential'' with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items, (2) whether and why such items are customarily treated as
confidential within the industry, (3) whether the information is
generally known by or available from other sources, (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality, (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure, (6) when such information might lose its
confidential character due to the passage of time, and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
DOE considers public participation to be a very important part of
the process for developing energy conservation standards. DOE actively
encourages the participation and interaction of the public during the
comment period in each stage of the rulemaking process. Interactions
with and between members of the public provide a balanced discussion of
the issues and assist DOE in the rulemaking process. Anyone who wishes
to be added to the DOE mailing list to receive future notices and
information about this process or would like to request a public
meeting should contact Appliance and Equipment Standards Program staff
at (202) 287-1445 or via email at
[email protected].
Signed in Washington, DC, on June 11, 2019.
Daniel R. Simmons,
Assistant Secretary, Energy Efficiency and Renewable Energy.
[FR Doc. 2019-12761 Filed 6-17-19; 8:45 am]
BILLING CODE 6450-01-P