US Department of Energy Adopts Higher Efficiency Standards for Distribution Transformers Michael Scholand, CLASP International Energy Efficient Transformers Workshop 2013 Bangkok, 13 November 2013 Purpose and Disclaimer • Review the new Distribution Transformer regulation adopted in the United States on 18 April 2013 • Compare with the previous requirements that were adopted in 2007 Important Disclaimer: I do not represent the US Department of Energy (DOE) nor the US Government. I worked as a contractor to DOE for 10 years, seven of which were spent on the 2007 regulation of Transformers. I did not work on the 2013 Final Rule. All the views expressed in this presentation represent my personal observations and understanding, and do not necessarily represent those of the DOE. 2 Table of Contents 1 Overview of US Transformer Programs 2 US Regulatory Program Process 3 Efficiency Levels Adopted 4 Benefits and Conclusions 3 Introduction Authority Energy Policy Act of 1992 (EPACT 1992) added Distribution Transformers Sec. 6317. Energy conservation standards for high-intensity discharge lamps, distribution transformers, and small electric motors (a) High-intensity discharge lamps and distribution transformers (1) The Secretary shall, within 30 months after October 24, 1992, prescribe testing requirements for those [ . . . ] distribution transformers for which the Secretary makes a determination that energy conservation standards would be technologically feasible and economically justified, and would result in significant energy savings. (2) The Secretary shall, within 18 months after the date on which testing requirements are prescribed by the Secretary pursuant to paragraph (1), prescribe, by rule, energy conservation standards for those [ . . . ] distribution transformers for which the Secretary prescribed testing requirements under paragraph (1). 4 Introduction Authority Detailed Timeline of US Activity • National Electrical Manufacturers Association (NEMA) developed a voluntary efficiency standard called “TP-1”, first published in 1996 and later revised in 2002 • US DOE initiated a series of market studies with Oak Ridge National Laboratory (1994-1997) • NEMA developed a test method for measuring transformer efficiency called “TP-2”, first published in 1998 and later revised in 2005 • US DOE initiated work on test procedures in 1996, which was completed in 2006 • US EPA created the ENERGY STAR Transformers in 1999 to help accelerate market adoption of NEMA TP-1 levels (focus was on low-voltage dry-type) • US DOE initiated work on the energy conservation standard (i.e., minimum energy performance standards) in 2000, and it was completed in 2007 • Congress passed the Energy Policy Act of 2005 establishing energy conservation standards for certain distribution transformers - low-voltage dry-type • US EPA stopped ENERGY STAR Transformers in May 2007, because same level as EPACT 2005 • NEMA launches NEMA Premium Transformers for low-voltage dry-type in May 2010 • US DOE initiated its review of the 2007 regulation in early 2011 • DOE completed its review and published the updated efficiency standards for Distribution Transformers on 13 April 2013 5 Introduction Authority Timeline of US Activity on Distribution Transformers • A combination of voluntary (grey) and mandatory (purple) programs • However, the mandatory programs have had more impact on the market NEMA publishes TP-1 1992 EPACT 1992 NEMA publishes TP-2 1996 ORNL studies EPA’s ENERGY STAR Transformers TP-1 and TP-2 revised 2000 Test Procedure Energy Conservation Regulation (first one) 2004 NEMA Premium Transformers 2008 DOE Efficiency Regulation Final Rule EPACT 2005 for LV drytype 2012 2016 DOE Energy Efficiency Revision Effective date of first DOE regulation Effective date of revised DOE regulation 6 Table of Contents 1 Overview of US Transformer Programs 2 US Regulatory Program Process 3 Efficiency Levels Adopted 4 Benefits and Conclusions 7 Regulatory Process Authority Mandatory Requirements • Two main ways to set mandatory efficiency requirements for products and equipment in the US: 1. Congress (Legislative) develops and adopts a bill and the President signs it into law (EPACT 2005 – LV Dry) 2. Congress empowers the US Department of Energy (DOE) to conduct a rulemaking • • Open process with defined stages • DOE publishes analysis, stakeholders comment • Final rule establishes requirements taking all viewpoints into consideration Recently, DOE added a new procedure under the Federal Advisory Committee Act and the Negotiated Rulemaking Act • Negotiated Rulemaking – form an expert committee of stakeholders and agree a level, propose it to DOE 8 Regulatory Process Authority DOE Regulations on Transformers • • The 2007 DOE transformer rulemaking followed traditional approach • Proposed requirements followed by stakeholder review and meetings • Revised proposal, followed by review and ultimately the Final Rule The 2013 DOE transformer rulemaking started with a ‘negotiated rulemaking’ • Formed a committee of stakeholders (industry, utilities, associations, environmental groups) who tried to reach consensus on an efficiency proposal • Met approximately 10 times, shared data, real-time discussion and understanding of view points, however could not agree • DOE therefore reverted to traditional approach, but at second step – revised proposal, followed by review and meetings and based on the data from the negotiated rulemaking (N.B. this effort was not wasted) • DOE published the updated Final Rule on 18 April 2013 Link: http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0048-0762 9 Regulatory Process Methodology Summary Negotiated Rulemaking – Data Example NEMA said although this process did not reach consensus, they found it much better for enabling all stakeholders to understand their viewpoint – data and discussion in real time. 10 Regulatory Process EPCA Criteria Energy Policy and Conservation Act (EPCA) requires DOE to consider 7 factors when setting efficiency standards Factor Analysis 1. Economic impact on consumers and manufacturers Life-cycle cost analysis Manufacturer impact analysis 2. Lifetime operating cost savings Life-cycle cost analysis 3. Total projected energy savings National 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 Regulatory KeyProcess Analyses Four Key Analyses of Standards Rulemaking • Engineering Analysis The relationship between cost and efficiency • Life-Cycle Cost Assessment The savings (or costs) that accrue to transformer customers • National Impacts Analysis The benefits (or costs) to the nation from the regulation • Manufacturer Impact Analysis The impact (positive/negative) on manufacturers from the regulation • Together, these four analyses cover 6 of the 7 EPCA factors 12 Regulatory Process Background Scope of Coverage* 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; viii.Sealed transformer; ii. Drive (isolation) transformer; ix. Special-impedance transformer; iii. Grounding transformer; x. Testing transformer; iv. Machine-tool (control) xi. Transformer with tap range transformer; of 20% or more; v. Non-ventilated transformer; xii. Uninterruptible power supply transformer; or vi. Rectifier transformer; xiii.Welding transformer. vii. Regulating transformer; * Scope of Coverage from 2013 Energy Conservation Standard Final Rule. Table of Contents 1 Overview of US Transformer Programs 2 US Regulatory Program Process 3 Efficiency Levels Adopted 4 Benefits and Conclusions 14 Efficiency Levels Cross-cutting Issues Liquid-Immersed Distribution Transformers Single-Phase Efficiency (% at 50% load) kVA 2010 2016 10 98.62 98.70 15 98.76 98.82 25 98.91 98.95 37.5 99.01 99.05 50 99.08 99.11 75 99.17 99.19 100 99.23 99.25 167 99.25 99.33 250 99.32 99.39 333 99.36 99.43 500 99.42 99.49 667 99.46 99.52 833 99.49 99.55 Three-Phase Efficiency (% at 50% load) kVA 2010 2016 15 98.36 98.65 30 98.62 98.83 45 98.76 98.92 75 98.91 99.03 112.5 99.01 99.11 150 99.08 99.16 225 99.17 99.23 300 99.23 99.27 500 99.25 99.35 750 99.32 99.40 1000 99.36 99.43 1500 99.42 99.48 2000 99.46 99.51 2500 99.49 99.53 Note: All efficiency values are at 50 percent of nameplate-rated load, determined according to the DOE Test-Procedure. 10 CFR Part 431, Subpart K, Appendix A. 15 Efficiency Levels Cross-cutting Issues Liquid-Immersed Distribution Transformers Note: All efficiency values are at 50 percent of nameplate-rated load, determined according to the DOE Test-Procedure. 10 CFR Part 431, Subpart K, Appendix A. 16 Efficiency Levels Cross-cutting Issues Medium-Voltage Dry-Type Distribution Transformers Single-Phase – No Change kVA 15 25 37.5 50 75 100 167 250 333 500 667 833 2010 Single Phase Efficiency (%) 20–45kV 46–95kV ≥96kV BIL BIL BIL 98.10 97.86 98.33 98.12 98.49 98.30 98.60 98.42 98.73 98.57 98.53 98.82 98.67 98.63 98.96 98.83 98.80 99.07 98.95 98.91 99.14 99.03 98.99 99.22 99.12 99.09 99.27 99.18 99.15 99.31 99.23 99.20 kVA 15 25 37.5 50 75 100 167 250 333 500 667 833 2016 Single Phase Efficiency (%) 20–45kV 46–95kV ≥96kV BIL BIL BIL 98.10 98.33 98.49 98.60 98.73 98.82 98.96 99.07 99.14 99.22 99.27 99.31 97.86 98.12 98.30 98.42 98.57 98.67 98.83 98.95 99.03 99.12 99.18 99.23 98.53 98.63 98.80 98.91 98.99 99.09 99.15 99.20 Note: All efficiency values are at 50 percent of nameplate-rated load, determined according to the DOE TestProcedure. 10 CFR Part 431, Subpart K, Appendix A. 17 Efficiency Levels Cross-cutting Issues Medium-Voltage Dry-Type Distribution Transformers Three-Phase kVA 15 30 45 75 112.5 150 225 300 500 750 1,000 1,500 2,000 2,500 2010 Three-Phase Efficiency (%) 20–45kV 46–95kV ≥96kV BIL BIL BIL 97.50 97.18 97.90 97.63 98.10 97.86 98.33 98.12 98.49 98.30 98.60 98.42 98.73 98.57 98.53 98.82 98.67 98.63 98.96 98.83 98.80 99.07 98.95 98.91 99.14 99.03 98.99 99.22 99.12 99.09 99.27 99.18 99.15 99.31 99.23 99.20 kVA 15 30 45 75 112.5 150 225 300 500 750 1,000 1,500 2,000 2,500 2016 Three-Phase Efficiency (%) 20–45kV 46–95kV ≥96kV BIL BIL BIL 97.50 97.18 97.90 97.63 98.10 97.86 98.33 98.13 98.52 98.36 98.65 98.51 98.82 98.69 98.57 98.93 98.81 98.69 99.09 98.99 98.89 99.21 99.12 99.02 99.28 99.20 99.11 99.37 99.30 99.21 99.43 99.36 99.28 99.47 99.41 99.33 Note: All efficiency values are at 50 percent of nameplate-rated load, determined according to the DOE TestProcedure. 10 CFR Part 431, Subpart K, Appendix A. 18 Efficiency Levels Cross-cutting Issues Medium-Voltage Dry-Type Distribution Transformers Three-Phase (10-200 kVA) Note: All efficiency values are at 50 percent of nameplate-rated load, determined according to the DOE Test-Procedure. 10 CFR Part 431, Subpart K, Appendix A. 19 Efficiency Levels Cross-cutting Issues Medium-Voltage Dry-Type Distribution Transformers Three-Phase (200-3000 kVA) Note: All efficiency values are at 50 percent of nameplate-rated load, determined according to the DOE Test-Procedure. 10 CFR Part 431, Subpart K, Appendix A. 20 Efficiency Levels Cross-cutting Issues Low-Voltage Dry-Type Transformers Single and Three-Phase Single-Phase Efficiency (% at 35% load) kVA 2010 2016 15 97.7 97.70 25 98.0 98.00 37.5 98.2 98.20 50 98.3 98.30 75 98.5 98.50 100 98.6 98.60 167 98.7 98.70 250 98.8 98.80 333 98.9 98.90 Three-Phase Efficiency (% at 35% load) kVA 2010 2016 15 97.0 97.89 30 97.5 98.23 45 97.7 98.40 75 98.0 98.60 112.5 98.2 98.74 150 98.3 98.83 225 98.5 98.94 300 98.6 99.02 500 98.7 99.14 750 98.8 99.23 1000 98.9 99.28 Single-Phase NEMA Premium kVA % Eff35 15 98.39 % 25 98.60 % 37.5 98.74 % 50 98.81 % 75 98.95 % 100 99.02 % 167 99.09 % 250 99.16 % 333 99.23 % Three-Phase NEMA Premium kVA % Eff35 15 97.90 % 30 98.25 % 45 98.39 % 75 98.60 % 112.5 98.74 % 150 98.81 % 225 98.95 % 300 99.02 % 500 99.09 % 750 99.16 % 1000 99.23 % Note: All efficiency values are at 35 percent of nameplate-rated load, determined according to the DOE Test-Procedure. 10 CFR Part 431, Subpart K, Appendix A. 21 Efficiency Levels Cross-cutting Issues Low-Voltage Dry-Type Transformers Single and Three-Phase Note: All efficiency values are at 35 percent of nameplate-rated load, determined according to the DOE Test-Procedure. 10 CFR Part 431, Subpart K, Appendix A. 22 Table of Contents 1 Overview of US Transformer Programs 2 US Regulatory Program Process 3 Efficiency Levels Adopted 4 Benefits and Conclusions 23 Benefits and Conclusions Cross-cutting Issues Regulatory Benefits to the Nation Considering equipment sold over a 30 year period (2016 to 2045), DOE estimates the following benefits to the nation from the new regulation: $12.9 billion in total costs to consumers — saving families and businesses money while also reducing energy consumption 3.63 quadrillion British thermal units of energy (approx. 1064 TWh) Compared to the 2007 regulation, electrical losses decreased by about: 8% for liquid-immersed transformers 13% for medium-voltage dry-type transformers, and 18% for low-voltage dry-type transformers Avoids ~264.7 million metric tons of CO2 emissions, equivalent to the annual emissions of about 51.75 million automobiles 24 Issues and Lessons Cross-cutting Issues Some concluding remarks... The US has 15+ years of experience with voluntary and mandatory programs on distribution transformers Voluntary programs didn’t have a large market impact, but they encouraged manufacturers to innovate and offer high-efficiency models Mandatory programs achieve energy saving objectives, but level of ambition must be set carefully, balancing technical and economic factors DOE increased the ambition of its regulations on nearly all Distribution Transformers starting from 2016 It started as a negotiated rulemaking (DOE’s first), and was completed as a traditional rulemaking Data from the negotiation was extremely valuable and all participants came to understand the diverse viewpoints of the different stakeholders 25 Final Slide Activity Summary Thank you for your Attention. Are there any Questions? 26