2011-08-29 Nominations for the proposed committee to review the efficiencies of distribution transformers.

The Department of Energy is in the process of creating a committee (EERE-2011-BT-STD-0051-0001) to review the efficiencies of distribution transformers (these are the typical transformers that you would see hanging on power poles serving homes and businesses). The proposed committee does not include representatives from public power systems or distribution systems – the very folks (other than the ultimate consumers) who would be most affected by the proposed changes. The proposed changes include increasing energy efficiency ratings on transformers. Although our entire industry promotes energy conservation, this proposal has several flaws: 1) To meet the proposed ratings, the new transformers would require amorphous core steel that is costly and rare. 2) The proposed transformers would be heavier than those presently in service, requiring bigger, more expensive poles for mounting. The ultimate result will be a slight savings in power usage that is more than offset by the additional costs incurred to make and mount the transformers. In other words, it will end up costing the end consumer MORE money than presently used materials. Many of the proposed committee members are manufacturers of the materials and products that will be mandated -- it is doubtful that they can be candid and open minded about these types of issues based upon their institutional biases. We urge the DOE to make sure that TRUE stakeholders in the system are included in the decision making process. Both Steve Harmon and Rody Blevins are CEO's at distribution cooperatives, and as such would add keen insight into the practical aspects of any proposed changes. We would ask that you consider adding them to your committee. Their resumes are attached.