The proposed regulatory…

The proposed regulatory change (O. Reg 404/12) for oil filled distribution transformer is quite odd, as it proposes to replace an existing National Canadian Standard by a US based regulation. The first issue of the Canadian standard for minimum efficiency for transformers was published in 1994(CSA C802-94); it was replaced by several individual standards in 2000, specifically C802.1 for oil filled distribution transformers.

Both the CSA committee and subcommittee working on this standard (CAN CSA C802.1) have been very active, and both do include a representative of the Ontario Ministry of Energy as members; this committee has met several times in Toronto, and reaffirmed + revised this standard on a timely basis.

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

-   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 unit 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 better, some may be worse. If the same “basic model” is sent to 3 different customers, they cannot individually verify if the units they received meet the RE value….

-   As CSA C802.1 does not allow for tolerance, manufacturers must make sure “their” average efficiency is at least 3 sigmas better than the table 1 value, to minimize the possible rejects or rework. So while the DOE 2016 efficiencies look better than the C802.1 by a small 0.2 -0.5 % point depending on the kVA rating, a unit manufactured to CSA C802.1 may well have a better efficiency.The table values of CSA C802.1 and the DOE cannot be directly compared.

-   It is clear that the DOE rule is not workable on an Ontario level only, as the same “basic model”may be shipped in other jurisdictions in Canada.

-   Applying the DOE rule, indicates as well a reporting aspect from each manufacturer to the Ontario government, adding bureaucracy and costs; supplying oil filled distribution transformers in Ontario will be more costly, and the LDC will pass on the extra capital cost by applying to the OEB for a kWhr rate increase.

-   The scope of the units covered is not the same and the DOE does not cover the efficiency for the 3000kVA units, and only covers for units with a LV voltage of 600V and less.

All in all, I do not see this proposal as adding much value in the chain, and on the opposite trying to displace an active and valid National Standard of Canada by a regulation tailored by the US;

I would like to end indicating that oil filled distribution transformers have an efficiency higher than 98.5%, and that any improvements towards the technically impossible 100% brings exponentially higher costs. The value for the dollar spent becomes minimal, if not overall negative, and for sure there are many other low hanging fruits with current efficiencies between 60 and 80% where the dollar spend would add considerable value from an energy point of view.

[Original Comment ID: 209966]