[Federal Register: February 9, 2007 (Volume 72, Number 27)]
[Proposed Rules]
[Page 6186-6190]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr09fe07-13]
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DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
10 CFR Part 431
[Docket Number: EE-RM/STD-00-550]
RIN 1904-AB08
Energy Conservation Program for Commercial Equipment:
Distribution Transformers Energy Conservation Standards
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of data availability and request for comments.
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SUMMARY: The Department of Energy (DOE) issued a notice of proposed
rulemaking (NOPR) for liquid-immersed and medium-voltage, dry-type
distribution transformers under the Energy Policy and Conservation Act
(EPCA). In response to this notice, stakeholders commented that DOE's
standard may prevent or render impractical the replacement of
distribution transformers in certain space-constrained (e.g., vault)
installations. Some stakeholders suggested that DOE's analysis of the
benefits and burdens of the proposed standard should take into
consideration the potential impacts of replacing transformers in space-
constrained vaults. In the Notice of Proposed Rulemaking (NOPR), DOE
factored weight-dependent installation costs in the analysis, but did
not specifically address potential costs related to transformers
installed in vaults. In today's notice, DOE requests comment on
inclusion of potential costs related to size constraints of
transformers installed in vaults. DOE also is considering an additional
option for the final efficiency levels for liquid-immersed distribution
transformers and by this notice invites public comment on this
additional option.
DATES: DOE will accept written comments, data, and information in
response to this notice, but no later than March 12, 2007. See section
VI, ``Public Participation,'' of this notice for details.
ADDRESSES: Any comments submitted must identify the Notice of Data
Availability for Distribution Transformers Energy Conservation
Standards, and provide the docket number EE-RM/STD-00-550 and/or
Regulatory Information Number (RIN) 1904-AB08. Comments may be
submitted using any of the following methods:
[[Page 6187]]
1. Federal eRulemaking Portal: http://www.regulations.gov. Follow
the instructions for submitting comments.
2. E-mail: TransformerNOPRComment@ee.[fxsp0]doe.[fxsp0]gov. Include
the docket number EE-RM/STD-00-550 and/or RIN 1904-AB08 in the subject
line of the message.
3. Mail: Ms. Brenda Edwards-Jones, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, 1000 Independence
Avenue, SW., Washington, DC 20585-0121. Please submit one signed
original paper copy.
4. Hand Delivery/Courier: Ms. Brenda Edwards-Jones, U.S. Department
of Energy, Building Technologies Program, Room 1J-018, 1000
Independence Avenue, SW., Washington, DC 20585. Telephone: (202) 586-
2945. Please submit one signed original paper copy.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section VI. of this document
(Public Participation).
Docket: For access to the docket to read background documents or
comments received, visit the U.S. Department of Energy, Forrestal
Building, Room 1J-018 (Resource Room of the Building Technologies
Program), 1000 Independence Avenue, SW., Washington, DC, (202) 586-
2945, between 9 a.m. and 4 p.m., Monday through Friday, except Federal
holidays. Please call Ms. Brenda Edwards-Jones at the above telephone
number for additional information regarding visiting the Resource Room.
Please note: DOE's Freedom of Information Reading Room (formerly Room
1E-190 at the Forrestal Building) is no longer housing rulemaking
materials.
FOR FURTHER INFORMATION CONTACT: Antonio Bouza, Project Manager, Energy
Conservation Standards for Distribution Transformers, U.S. Department
of Energy, Building Technologies Program, Mailstop EE-2J, 1000
Independence Avenue, SW., Washington, DC 20585-0121, (202) 586-4563, e-
mail: Antonio.Bouza@ee.[fxsp0]doe.[fxsp0]gov.
Francine Pinto, Esq. or Chris Calamita, Esq., U.S. Department of
Energy, Office of General Counsel, Mailstop GC-72, 1000 Independence
Avenue, SW., Washington, DC 20585, (202) 586-7432, e-mail:
Francine.[fxsp0]Pinto@hq.[fxsp0]doe.[fxsp0]gov. or
Christopher.[fxsp0]Calamita@hq.[fxsp0]doe.[fxsp0]gov.
SUPPLEMENTARY INFORMATION:
I. Introduction
II. Transformer Size Issues
A. DOE's Treatment of Size Issues in the NOPR Analysis
B. Summary of Comments on Size Issues for Vault Transformers
C. Size Constraints in DOE's NOPR Analysis
III. DOE's Proposed Revisions to Estimating Size Burdens
A. Vault Transformer Subgroup Analysis
B. Addressing Size Constraints for Vault Transformers
C. Potential Approaches for Estimating the Cost Impacts of
Satisfying Constraints Without Vault Modifications
D. Potential Approaches for Estimating the Cost Impacts of
Satisfying Constraints With Vault Modifications
IV. Summary of Size Issue
V. Consideration of Final Efficiency Levels
VI. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
I. Introduction
Part C of Title III of EPCA authorizes DOE to establish energy
conservation standards for distributions transformers for which DOE
determines that energy conservation standards would be technologically
feasible and economically justified, and would result in significant
energy savings. (42 U.S.C. 6317(a).) Pursuant to EPCA, DOE published a
NOPR for liquid-immersed and medium-voltage, dry-type distribution
transformers on August 4, 2006. 71 FR 44356. Together with the NOPR,
DOE published a technical support document (TSD) that details each
analysis DOE conducted for the rulemaking, providing specific
information on its methodology and results. These documents are
available at the following DOE Web site: http://www.eere.energy.gov/buildings/appliance_standards/commercial/distribution_transformers.html.
DOE subsequently held a public meeting on September
27, 2006, and invited comments from stakeholders until October 18,
2006.
Some stakeholders commented that DOE had not properly considered
potentially significant economic impacts of the minimum efficiency
standard on space-constrained vault transformer installations. Vault
transformers are distribution transformers that are used in underground
distribution networks, where the transformers are installed below
ground level. Often found in urban areas, these transformers are
installed inside a concrete vault that is open at the top, which can be
very expensive to replace or expand. As transformers are manufactured
to be more energy efficient, they tend to increase in size. For this
reason, stakeholders expressed concern that DOE's mandatory standard
may not allow for practical replacement of transformers in certain
existing space constrained installations.
In the analysis for the NOPR, DOE considered potential weight-
dependent costs for installation, but DOE did not factor potential
space-constraint costs of vault transformers in its analysis. DOE
acknowledges the concern with space-constrained installations, and in
this notice outlines for stakeholder comment analytical approaches that
take into consideration potential costs related to distribution
transformers installed in vaults.
This notice presents analytical approaches DOE is considering for
addressing stakeholder concern on the space-constrained vault
transformer issue. DOE invites stakeholders to comment on these
approaches, or to propose alternatives to DOE.
II. Transformer Size Issues
A. DOE's Treatment of Size Issues in the NOPR Analysis
In the life-cycle cost (LCC) spreadsheets DOE published with the
NOPR, DOE provided external dimensions and weight information for each
of the distribution transformer designs it considered in its analysis.
For distribution transformers, size is very closely correlated with
weight, and DOE developed weight-dependent installation costs for
transformers using scaling relationships developed from RS Means
installation cost data (see TSD, Chapter 7).
Although DOE's LCC spreadsheets contained external dimensional
information for each transformer in the design database, DOE's NOPR did
not report transformer size as a function of trial standard level
(TSL). For today's notice, DOE calculated the volumes of those
transformers selected by the LCC spreadsheets, as a function of TSL,
for the two design lines (DLs) for which transformer vault constraints
are most likely to be an issue: DL4 and DL5.\1\ Tables II.1 and II.2
provide the average volume distributions for DL4 and DL5, respectively.
For these tables, DOE sorted the transformers from the smallest to the
largest volume for the distribution of transformers purchased at each
standard level. DOE then calculated the minimum volume, the maximum
volume, and the transformer volume at the 10th, 25th, 50th, 75th,
[[Page 6188]]
and 90th percentiles. These distributions illustrate the degree to
which average transformer volumes of selected designs in the NOPR LCC
analysis varied by TSL.
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\1\ DL4 includes 15-500 kilovolt-ampere (kVA) liquid-immersed,
three-phase transformers, and is represented in the LCC analysis by
a 150 kVA transformer. DL5 includes 750-2500 kVA liquid-immersed,
three-phase transformers, and is represented in the LCC analysis by
a 1500 kVA transformer.
Table II.1.--Transformer Volume in Cubic Feet, NOPR LCC Results for Design Line 4 (150 kVA)
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Design line 4 Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6
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Minimum..................... 61.11 63.89 66.55 66.41 66.41 80.24 87.50
10th percentile............. 62.50 66.41 69.01 69.01 69.01 80.24 87.50
25th percentile............. 64.93 67.71 69.36 70.54 70.54 80.24 87.50
50th percentile............. 69.01 71.61 75.14 75.87 75.87 81.60 87.50
75th percentile............. 75.87 76.16 78.88 81.60 81.60 86.11 88.89
90th percentile............. 81.94 81.94 81.94 85.68 85.68 87.04 88.89
Maximum..................... 90.28 90.28 91.67 91.67 91.67 91.67 90.74
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Table II.2.--Transformer Volume in Cubic Feet, NOPR LCC Results for Design Line 5 (1500 kVA)
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Design line 5 Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6
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Minimum..................... 202.22 223.81 222.96 229.93 233.41 247.35 247.35
10th percentile............. 215.91 227.99 233.41 233.41 236.90 250.83 250.83
25th percentile............. 226.45 233.41 236.90 233.41 236.90 257.80 257.80
50th percentile............. 236.90 236.90 240.38 240.38 240.38 257.80 257.80
75th percentile............. 240.38 240.38 241.03 243.87 247.35 257.80 257.80
90th percentile............. 250.83 250.83 250.83 250.83 250.83 257.80 257.80
Maximum..................... 261.28 261.28 261.28 261.28 261.28 257.80 257.80
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Relative to the base case for DL4, the increase in volume of the
smallest transformer (i.e., ``minimum'') is nine percent or less for
TSL4 and lower, while the largest transformer (i.e., ``maximum'') has
an increase in volume relative to the base case of two percent or less
for TSL4 and lower.
Relative to the base case for DL5, the increase in volume of the
smallest transformer is 16 percent or less for TSL4 and lower, while
the largest transformer has no increase in volume.
B. Summary of Comments on Size Issues for Vault Transformers
DOE received comments on both size and weight issues from
stakeholders during both the advance notice of proposed rulemaking
(ANOPR) and NOPR phases of the rulemaking. In the NOPR, DOE requested
comment on ``whether the Department should include space occupancy
costs in the cost of transformers as a means of accounting for space
constraints.'' 71 FR 44407. In response to this request, commenters
provided feedback both during the public meeting and in their written
comments.
HVOLT commented that it endorsed the concept of using space
occupancy costs in the evaluation of the impacts of space-constrained
utility transformers. (Public Meeting Transcript, No. 108.6 at p. 129)
The American Council for an Energy Efficient Economy (ACEEE)
recommended that DOE calculate what ``the average cost of a vault
modification is times the percentage of applications that will
trigger.'' (Public Meeting Transcript, No. 108.6 at p. 130) The Edison
Electric Institute (EEI) commented that space occupancy costs should be
included but that such costs may be difficult to estimate and may range
from 10 percent of the cost of a transformer to 100 percent of the
transformer cost. (Public Meeting Transcript, No. 108.6 at p. 129-130)
In written comments after the NOPR public meeting, ACEEE commented
that vault transformer costs should be treated using methods similar to
the methods DOE used for distribution transformer pole costs in the
NOPR analysis. (ACEEE, No. 127 at p. 6) EEI, in its written comments,
emphasized the importance of the potential costs for vault transformers
since this effect could create serious service reliability issues for
some utilities. (EEI, No. 137 at p. 3)
In its comments and submissions in response to the ANOPR, EEI
provided limited data on potential costs that could be applicable to
vault transformers. (EEI, No. 63 at pp. 20-62) In its submission, EEI
provided a survey in which it asked its members, as well as members of
the American Public Power Association (APPA) and the National Rural
Electric Cooperative Association (NRECA), the following question: ``For
currently existing pad-mount units in urban areas that need to be
replaced, what kind of impact would a 10%, 25%, or 50% size increase
have on the installed costs?'' EEI received nine responses from its
members, eight responses from APPA members, and one response from an
NRECA member. EEI packaged all these responses and provided them to the
DOE as one comment. Of these responses, a few were directly relevant to
vault transformers, with most responses noting some impact but not
quantifying the size of the impacts. EEI member 6 commented
that ``Should the transformer pad or vault lid require replacement in
order to fit the larger transformer, then additional costs ranging from
$500 to $1,500 will apply.'' (EEI, No. 63 at p. 36) At the high end of
cost estimates, APPA member 5 commented that ``size would be
an issue if we had to change out units to larger. Cost per location can
cost approx. $15k.'' (EEI, No. 63 at p. 42) Other EEI, APPA, or NRECA
members did not provide specific estimates for relocation, vault
replacement, or vault modification costs for vault transformers.
C. Size Constraints in DOE's NOPR Analysis
While DOE did include size-dependent installation costs for
distribution transformers in its analysis (see NOPR TSD, Chapter 7), it
did not include the additional space-constraint costs that may be borne
by vault transformers. Since stakeholders presented this issue as a
substantial concern in their comments on the NOPR, and since DOE agrees
that it did not include these costs in the NOPR analysis, DOE intends
to consider these costs in its analysis for the final rule.
[[Page 6189]]
III. DOE's Proposed Revisions to Estimating Size Burdens
A. Vault Transformer Subgroup Analysis
In response to the stakeholder comments summarized above, DOE
intends to conduct a subgroup sensitivity analysis of vault
transformers to estimate space-constraint costs for the final rule.
This issue is primarily of concern for liquid-immersed, three-phase
distribution transformers, as this type of transformer is most often
used in vault applications. Therefore DOE intends to conduct its
sensitivity analysis on its two design lines that represent three-phase
liquid-immersed distribution transformers, DL4 and DL5.
Information provided by Howard Industries suggests that less than
0.5 percent of transformers are used in submersible or vault
applications. (Howard Industries, No. 143 at p.5) Taking that estimate
of 0.5 percent of all liquid-immersed transformers are vault
transformers, and assuming they are all large, three-phase units such
as those in DL5, the percentage of vault transformers could account for
a sizeable portion of total DL5 sales--perhaps as high as 25 percent.
If the estimate of 0.5 percent of all liquid-immersed shipments were
instead assumed to all be smaller three-phase transformers (i.e., DL4),
the fraction of DL4 transformers affected by such space constraints is
likely to be less than a few percent. Stakeholders are invited to
comment on the proportion of distribution transformers sold that are
installed in underground vaults, particularly with respect to the
liquid-immersed, three-phase design lines, DL4 and DL5.
B. Addressing Size Constraints for Vault Transformers
DOE recognizes that, where vault dimensional constraints are an
issue, transformer customers have several options available to them,
including:
1. Rewinding or refurbishing the existing transformer,
2. Purchasing a lower-kVA transformer and subjecting it to higher
loading (or re-routing part of the load served),
3. Purchasing a transformer--constructed of higher-performing core
steel and/or other materials--that is standards-compliant without being
significantly larger (with added cost),
4. Rebuilding or expanding the existing vault, or
5. Petitioning DOE for waiver from energy conservation standard
requirements.
DOE expects that the first two options, if available, would be
cheaper than purchasing a new transformer. DOE therefore proposes to
focus its analysis of the LCC impacts from dimensionally constrained
vault transformers on the third and fourth options as part of an LCC
subgroup analysis published with the final rule.
C. Potential Approaches for Estimating the Cost Impacts of Satisfying
Constraints Without Vault Modifications
Considering option 3 from the above list, DOE could estimate the
cost of purchasing a transformer of the same size, but constructed of
higher-performing materials, such as better grades of core steel or
copper conductor, by performing a size-constrained LCC calculation for
both DL4 and DL5. In this calculation, DOE could assume the standards-
compliant transformer in the LCC calculation was constrained at certain
sizes, e.g., at the 25th and 50th percentiles of the distribution
transformer volumes in the base case.
As a function of standard level, DOE could then run the LCC
spreadsheets and calculate the LCC of the space-constrained
transformers (at prescribed dimensional percentiles), and compare those
values to the LCC from the unconstrained transformer analysis. The
difference in LCC between the two cases would quantify the impact of
satisfying the space constraint with better materials as a function of
efficiency level for that subgroup of dimensionally constrained vault
transformers.
D. Potential Approaches for Estimating the Cost Impacts of Satisfying
Constraints With Vault Modifications
Considering option 4 from the above list, DOE could add an
additional size-dependent installation cost to the transformers
included in the LCC subgroup analysis for vault transformers to account
for a relatively high underground vault-space cost. DOE invites
additional stakeholder input or data on what would be reasonable fixed
and variable costs (e.g., per cubic foot) for DL4 and DL5. For this
option, DOE would apply the vault replacement costs (with both a fixed
and variable cost) when a transformer exceeds the median volume of the
transformers in the base case. Given a review of cost estimation data
for utility vault reconstruction, the Department currently estimates a
fixed cost for vault replacement of $1740 per vault and a variable cost
of $26 per cubic foot of transformer. Vault replacement may be required
for the higher TSLs (TSL5 and above for both DL4 and DL5). In its
standard LCC calculation, DOE based transformer selection on the
manufacturer selling price. For this calculation, however, DOE proposes
to assume that the customer choice of transformer design is based on
total installed cost because customers are likely to be conscious of
space constraint costs.
IV. Summary of Size Issue
DOE intends to consider space-constrained vault transformers as
part of the LCC subgroup analysis for the final rule. DOE seeks comment
from stakeholders on the proportion of distribution transformers sold
which are installed in underground vaults, particularly with respect to
the liquid-immersed, three-phase design lines, DL4 and DL5.
In this notice, DOE outlines different approaches as to how it
might account for those additional installation costs. DOE requests
that stakeholders review these approaches and provide comment on the
methodology and inputs. DOE intends to use the same LCC spreadsheet
tools for estimating LCC impacts on vault transformers, with minor
modifications, as it used to analyze the other LCC subgroups in the
NOPR (see NOPR TSD, Chapter 11).
V. Consideration of Final Efficiency Levels
DOE notes that in the NOPR, the proposed final standard for liquid-
immersed distribution transformers was based on the efficiency levels
presented in TSL 2. 71 FR 44407. While the proposed standard was based
on TSL 2, DOE-evaluated efficiency levels associated with a series of
TSLs. Analysis of the other TSLs indicated that some of the efficiency
levels set forth in TSL 3 and TSL 4 may be justifiable for specific
liquid-immersed distribution transformer designs and capacities. (See
Table IV.4 in 71 FR 44378 and Tables EA.3 through EA.10 in pages EA.6
through EA.13 of the Environmental Assessment Report published with the
NOPR TSD) Referencing this analysis, some commenters suggested that DOE
establish a final standard that incorporates higher efficiency levels
from other TSLs, which preliminarily appeared to comply with the
requirements of EPCA.
Based on the comments received to date, DOE is inclined to consider
a final standard that is based on efficiency levels from TSL 2 and/or 3
for three-phase, liquid-immersed, distribution transformers and
efficiency levels from TSL 2, 3, and/or 4 for single-phase liquid-
immersed, distribution transformers. Today's notice provides
[[Page 6190]]
stakeholders an opportunity to comment on this potential consideration.
VI. Public Participation
A. Submission of Comments
DOE will accept comments, data, and information regarding this
notice no later than the date provided at the beginning of this notice.
Comments, data, and information submitted to the Department's e-mail
address for this rulemaking should be provided in WordPerfect,
Microsoft Word, PDF, or text (ASCII) file format. Stakeholders should
avoid the use of special characters or any form of encryption, and
wherever possible, comments should include the electronic signature of
the author. Absent an electronic signature, comments submitted
electronically must be followed and authenticated by submitting a
signed original paper document to the address provided at the beginning
of this notice. Comments, data, and information submitted to the
Department via mail or hand delivery/courier should include one signed
original paper copy. No telefacsimiles (faxes) will be accepted.
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 two copies: One copy of the document including
all the information believed to be confidential, and one copy of the
document with the information believed to be confidential deleted. 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 or available from public 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) a date after which such information might no
longer be considered confidential; and (7) why disclosure of the
information would be contrary to the public interest.
B. Issues on Which DOE Seeks Comment
DOE is particularly interested in receiving comments and views of
interested parties concerning:
(1) The proportion of distribution transformers sold that are
installed in underground vaults, particularly with respect to the
liquid-immersed, three-phase design lines, DL4 and DL5,
(2) The assumption that typical space-constrained vault
transformers will be restricted to a volume that is approximately the
median size of baseline transformers, and
(3) The approaches proposed in this notice to account for LCC
impacts on space-constrained vault transformers, including the
methodology and inputs.
(4) The possibility of having a liquid-immersed standard level that
is based on efficiency levels from TSL 2 and/or 3 for three-phase and
TSL 2, 3, and/or 4 for single-phase.
Issued in Washington, DC, on February 2, 2007.
Alexander A. Karsner
Assistant Secretary, Energy Efficiency and Renewable Energy.
[FR Doc. E7-2168 Filed 2-8-07; 8:45 am]
BILLING CODE 6450-01-P