31 July 2017…

31 July 2017

Ontario Ministry of Energy
Conservation and Renewable Energy Division
Attn: Senka Krsikapa MSc. P. Eng. Manager
77 Grenville Street, Floor 5 & 6
Toronto ON
M7A 2C1

Dear Ms. Krsikapa

Comments on Update test method, scope and/or energy efficiency requirements for Liquid-Filled Distribution Transformers (Reg. 404/12 Energy and Water Efficiency – Appliances and Products)

Electro-Federation Canada (EFC) has significant concerns regarding the pending Ontario energy efficiency regulation for Liquid-Filled Distribution Transformers. The proposed amendment would harmonize, using rolling incorporation, the test method, scope and efficiency requirements with the corresponding requirements that came into force on 01 January 2016 under the United States Department of Energy (DOE) Regulation. Ontario’s proposed compliance date is 01 January 2019.

The regulatory change (O. Reg. 404/12) for Liquid-Filled Distribution Transformers proposes to replace an existing Canadian National Standard by a US based regulation. The first issue of the Canadian Standard (CSA C802-94) for minimum efficiency for transformers was published in 1994; it was replaced by several individual standards in 2000, specifically CAN/CSA C802.1-13 Minimum efficiency values for Liquid-Filled Distribution Transformers.

Both the CSA Technical Committee and Technical Subcommittee working on this standard (CAN/CSA C802.1) have been very active; and both do include a representative from the Ontario Ministry of Energy and Natural Resources Canada (NRCan). The committees have met regularly in Toronto to revise and reaffirm this standard on a timely basis so it remains current.

There are some major differences between both the CAN/CSA C802.1 and the DOE Regulation such that both cannot be efficiently used at the same time in Canada.

•   CAN/CSA C802.1 requires that each transformer must be tested and its efficiency meet the minimum requirement given in Table 1 of the standard: there is no tolerance. The DOE defines “basic models” rather than individual transformers, and allows sampling if more than 5 units are shipped within a 6 month period. DOE allows for tolerance on the Represented Efficiency (RE) required in their tables, and this tolerance is a function of the number of units tested and will be less than the published RE efficiency level. Further, that massaged efficiency number is the average value for the sample; some units may be more efficient, some may be less. If the same “basic model” is sent to three different customers, they cannot individually verify if the units they received meet the RE value.

• As CAN/CSA C802.1 does not allow for tolerance, manufacturers must make sure their “average efficiency” is at least 3 standard deviations (sigma) better than the Table 1 value to minimize the possibility of rejects or rework. While the DOE 2016 efficiencies appear to be better than the CAN/CSA C802.1 by a small 0.2% to 0.5% percentage depending on the kVA rating; a unit manufactured to CSA C802.1 may well have a better efficiency. The table values of CAN/CSA C802.1 and the DOE Regulation cannot be directly compared.

•  The scope of the units covered is not the same. The DOE Regulation does not cover the efficiency for 3000kVA units; and only covers units with a Low Voltage rating of 600 Volts and less.

This change has a negative impact on industry and users. While it copies the US DOE regulation; it will eventually require manufacturers to report losses in a yearly document to the government (at least to the Ontario Ministry of Energy) to ensure compliance and indicate the actions taken when the minimum efficiency is not met for some designs. Users no longer are able to verify compliance as all units do no longer have to meet the standard individually. It is understood under the DOE Regulation a unit not meeting efficiency sent to a User in Ontario, may be offset by one or more units of the same base design having a better efficiency being shipped to Users outside of Ontario. When the CAN/CSA C802.1 standard was written, the reason the committee chose to have each unit meet the efficiency level was to avoid the need for reporting efficiency data to the government.

To the best of EFC’s knowledge this proposed regulation is not harmonized with any other Canadian Provincial regulations. It appears the DOE regulations are not workable at an Ontario level only; as the same “basic model” transformer may be shipped to other jurisdictions in Canada. Applying the DOE regulation indicates there will be a reporting requirement from the Ontario Government to each manufacturer. This will add administrative cost to supplying liquid filled distribution transformers in Ontario; resulting in Local Distribution Companies passing the increased cost on to ratepayers in the form of increased energy rates.

Liquid-Filled Distribution Transformers have an efficiency rating of higher than 98.5%; improvements toward the technically impossible 100% come with exponentially higher costs. The value proposition of spending a dollar to increase efficiency has virtually reached the point of diminishing returns. There are other products where current efficiencies are in the range of 60 to 80% where a dollar spent would add considerable value from an energy efficiency point of view.

In summary EFC does not see this proposal adding much value in the supply chain; or add significant energy savings by displacing an active and valid National Standard of Canada by a regulation crafted by the US DOE.

Requested Action

Industry strongly recommends the Ontario Ministry of Energy withdraw the Liquid-Filled Distribution Transformer portion of the regulation that would replace the existing Canadian National Standard with the US Department of Energy Regulation.

The last reaffirmation of CAN/CSA C802.1 occurred in 2013 and is up for re-affirmation in 2018. It appears next year would be an opportune time to complete a review by the respective CSA Technical Sub-Committee (TSC). During the review the Ontario Ministry of Energy representative on the TSC can discuss components of the standard requiring revision with Utility and Industry members, NRCAN and other stakeholders as appropriate. This would allow Industry to recommend achievable improvements to an already nationally and provincially harmonized CAN/CSA C802.1 standard that will reflect sustainable transformer efficiency levels. In addition, it will avoid imposing an extra burden of cost to provide separate reporting to Ontario Regulators.

Please contact me at Electro-Federation Canada if there are questions or further information is required.

Thank you.

Yours truly,

Robert (Rob) McIntyre CPA CMA
Vice President, Technical Services
Electro-Federation Canada
180 Attwell Drive
Toronto, ON
M9W 6A9

rmcintyre@electrofed.com

CC Glenn Thibeault – Minister of Energy, Ontario
Richard de Lhorbe – Chair, CSA C501 Distribution Transformer TC
Sam Loggia – Manager, Strategic Initiatives, CSA
Yasser Salmi – Chair, Joint Transformer Product Section EFC
George Partyka – Vice Chair, Joint Transformer Product Section EFC
herith Sinasac – Manager, Product Sections EFC
Carol McGlogan – President / CEO Electro-Federation Canada

[Original Comment ID: 210699]