Recently the U.S. Department of Energy posted the Final Rule for the energy efficiency rulemaking for Distribution Transformers. http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/66
While some entities have criticized the Government’s final decision, the DOE Final Rule was largely on target. DOE worked through huge amounts of data from all sides and came to a fairly good result.
NEMA stuck to a few principles—backed up by data—throughout the negotiated rulemaking. We offered all this in this public forum and all parties were given the opportunity to discuss, debate, offering contrasting data, etc. Everyone should agree it was a very candid and productive process.
NEMA supported increasing efficiency standards to the highest level that were justified from a cost effectiveness perspective. NEMA is familiar with high efficiency transformers—our NEMA Premium program offers certain units that have 30% less loss than existing federal requirements. And our manufacturers are offering very high efficiencies on a daily basis to customers who demand them.
We were opposed to standards that would lead to an uncompetitive market. Any higher on the liquid filled side and manufacturers would be forced to use a single material currently provided in the U.S. by a single supplier. Flexibility in design and multiple materials suppliers are key to a healthy industry.
Another outcome that was avoided, thankfully, was making the cost of the new, more efficient units so high that electric utilities would choose to refurbish their old, less efficient units instead of buying new more efficient ones. That would have had an extremely negative effect on energy efficiency.
NEMA advocated on behalf of all stakeholders understanding the potential negative impacts on small manufacturing facilities if significantly higher efficiency standards were adopted. We remain concerned that the new levels for low voltage dry-type will have harmful effects of some of the smaller manufacturers.
But overall, we think DOE should be commended for a good rule and a great process to get there.