[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 http://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: http://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 http://www.regulations.gov. All documents in
the docket are listed in the http://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 http://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 http://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 http://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 http://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 http://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; http://www.eia.doe.gov/emeu/cbecs/microdat.html.
\30\ Manufacturing Energy Consumption Survey (MECS); 2006 U.S.
Department of Energy--Energy Information Administration; http://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\
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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
---------------------------------------------------------------------------
\47\ Barnes. Determination Analysis of Energy Conservation
Standards for Distribution Transformers. ORNL-6847. 1996.
---------------------------------------------------------------------------
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 http://www.regulations.gov. The http://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 http://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 http://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 http://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 http://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