1. DOE Distribution Transformer Efficiency Standards IEEE Rural Electric Power Conference Charleston, SC April 29, 2008 Bob Saint – Principal Distribution Engineer, Energy Policy NRECA Transmission & Distribution Engineering Committee (T&DEC)

2. DOE – Appliances and Commercial Equipment Standards Program Develops test procedures and minimum efficiency standards for residential appliances and commercial equipment Applies to products manufactured for sale in as well as those imported into the United States

3. Laws and Regulations The Energy Policy and Conservation Act (EPCA) of 1975 established an energy conservation program for major household appliances. The National Energy Conservation Policy Act of 1978 amended EPCA to add Part C of Title III, which established an energy conservation program for certain industrial equipment. The Energy Policy Act of 1992 amended EPCA to add certain commercial equipment, including distribution transformers.

4. Residential Products Battery Chargers & External Power Supplies Central Air Conditioners & Heat Pumps Clothes Dryers Clothes Washers Cooking Products Dehumidifiers Dishwashers Furnaces & Boilers Fluorescent & Incandescent Lamps Fluorescent Lamp Ballasts Plumbing Products Pool Heaters Refrigerators & Freezers Room Air Conditioners Small Duct, High Velocity Air Conditioners Torchieres Water Heaters

5. Commercial Equipment Heating, Air Conditioning and Water Heating Equipment Clothes Washers Distribution Transformers Electric Motors Furnaces & Boilers High Intensity Discharge Lamps Refrigerated Beverage Vending Machines Refrigeration Equipment Small Electric Motors Unitary Air Conditioners & Heat Pumps Water Heaters

6. Determination Analysis –Oak Ridge National Laboratory, 1994-1996 White Papers –"Based on its analysis of the information now available, the Department has determined that energy conservation standards for transformers appear to be technologically feasible and economically justified, and are likely to result in significant savings" (October 22, 1997). DOE Actions on Distribution Transformers

7. Test Procedure – started in 1998. –NOPR – November 12, 1998 –SNOPR – Public Meeting, September 27, 2004 –Final Rule, published on April 27, 2006. –Technical Correction, October 16, 2006

8. DOE Actions on Distribution Transformers Energy Conservation Standard – started in 2000. –Framework Document Workshop, November 1, 2000 –Draft analyses published 2001 through 2003 –ANOPR published July 29, 2004 Public Meeting, September 28, 2004 –EPAct 2005 establishes standards for Dry-type Transformers effective January 1, 2007 –NOPR, August 4, 2006 Public Meeting, September 27, 2006 –Final Rule Published October 12, 3007 Effective January 1, 2010

9. NRECA T&DEC System Planning Subcommittee Involvement Ken Winder - Moon Lake EA, Utah (lead) Commented on ANOPR and NOPR Met with Lawrence Berkeley National Laboratory Team – February 22, 2005 http://www.eere.energy.gov/buildings/ap pliance_standards/

10. The Energy Policy and Conservation Act directs DOE to take into consideration seven factors when setting energy conservation standards FactorAnalysis 1. Economic impact on consumers and manufacturers Life-cycle cost analysis Manufacturer impact analysis 2. Lifetime operating cost savingsLife-cycle cost analysis 3. Total projected energy savingsNational impact analysis 4. Impact on utility or performance Engineering analysis Screening analysis 5. Impact of any lessening of competition Manufacturer impact analysis 6. Need for national energy conservation National impact analysis 7. Other factors the Secretary considers relevant Environmental assessment Utility impact analysis Employment impact analysis

11. DOE Efficiency Calculations Efficiency = Power OUT/Power IN %EFF = 100 x kVA x 0.5 kVA x 0.5 + ((NL + LL x 0.91x 0.5 2 )/1000) Where: %EFF = Efficiency means the ration of the useful power to the total power input; for DOE Rule it is calculated at 50% Load kVA = Transformer Capacity in kilo-volt Amperes NL = No Load (Core) Losses corrected to 20 o C LL = Load Losses corrected to 85 o C 0.091 = Load Loss Temperature correction from 85 o C to 55 o C

12. Trial Standard Levels (TSLs) span levels from the voluntary industry standard to maximum technologically feasible. Six Trial Standard Levels were considered: –TSL1 = NEMA TP 1-2002 (industry voluntary standard) –TSL2 ~1/3 of the efficiency between TP 1 and Min LCC (TSL4) –TSL3 ~2/3 of the efficiency between TP 1 and Min LCC (TSL4) –TSL4 ~minimum life-cycle cost (LCC) –TSL5 ~maximum energy savings with no change in LCC –TSL6 = maximum technologically feasible Similar to the Candidate Standard Levels published in the ANOPR On liquid-immersed, some TSLs slightly modified for consistency or for core steel grouping

13. Industry Positions DOE NOPR, NRECA T&DEC – TSL2 NEMA – TSL1 (NEMA TP-1) EEI, APPA, Environmental Groups, ABB – TSL4

14. Single Phase Efficiency (%) kVANEMA TP-1TSL2Final RuleTSL4 1098.40 98.6298.48 1598.6098.5698.7698.63 2598.7098.7398.9198.79 37.598.8098.8599.0198.91 5098.90 99.0899.04 7599.0099.0499.1799.08 10099.0099.1099.2399.14 16799.1099.2199.25 25099.2099.2699.3299.45 33399.2099.3199.3699.49 50099.3099.3899.4299.54 66799.4099.4299.4699.57 83399.4099.4599.4999.60

16. Three Phase Efficiency (%) kVANEMA TP-1TSL2Final RuleTSL4 1598.1098.36 98.68 3098.4098.62 98.89 4598.6098.76 99.00 7598.7098.91 99.12 112.598.8099.01 99.20 15098.9099.08 99.26 22599.0099.17 99.33 30099.0099.23 99.38 50099.1099.3299.2599.45 75099.2099.2499.3299.37 100099.2099.2999.3699.41 150099.3099.3699.4299.47 200099.40 99.4699.51 250099.4099.4499.4999.53

18. Fraction of Transformers Purchased by Rural Electric Cooperatives that will be Affected by TSL2 Design LinekVAPhaseAffected, % LCC Savings, $ Payback Period, years 150149.8 $ 7912.4 225138.0 $ 667.6 3500135.1 $ 1,5255.7 4150361.5 $ 37022.2 51500337.6 $ 3,0138.4

19. Fraction of Transformers Purchased by Rural Electric Cooperatives that will be Affected by TSL4 Design LinekVAPhaseAffected, % LCC Savings, $ Payback Period, years 150198.0 $ 5825.2 225148.1 $ 6314 3500197.7 $ 1,57922.5 4150393.9 $ 18325.4 51500379.2 $ 3,23917.4

20. Summary of Distribution Transformer Analytical Results* DescriptionTSL2 Final RuleTSL4 Energy Saved (quads)2.32.743.4 Emission Reductions - CO 2 (million tons)158.2232232.8 400 MW power plants not built11616 *During the period 2010-2038

21. Legal Actions The State of California along with Sierra Club, and NRDC filed a lawsuit against DOE, claiming that it failed to follow the requirements of the National Environmental Policy Act –The States of New York, New Jersey, and Connecticut as well as New York City have filed to intervene on the side of California –NEMA filed to intervene on the side of DOE NEMA does not anticipate a ruling before year end 2008 Consensus is that the current DOE Rules will be implemented as stated in 1/1/2010, with possible increased efficiencies to follow