My comments are related to…

My comments are related to liquid-filled transformer efficiencies; specifically the proposal for Ontario to adopt the US Department of Energy (DOE) 2016 efficiency levels for liquid-filled transformers.

"Liquid-filled distribution transformers: The proposed amendment would harmonize, using rollingincorporation, the test method, scope and efficiency requirements with the correspondingrequirements that came into force on January 1, 2016 under the DOE Regulation. Ontario’s proposedcompliance date is January 1, 2019"

I've been designing liquid-filled transformers for Canada and the US for more than 20 years and Ihave been involved in the development of the CSA energy efficiency standards for liquid-filledtransformers, C802.1 and C802.3. My comments are my personal opinions, based on years ofexperience designing transformers with various requirements for many locations, they do notrepresent my employer.

1) DOE 2016 efficiencies levels are good; in most cases the energy savings will pay for the increased cost of the transformer and any reduction in carbon dioxide emissions is a bonus. They aren't as good as they could be, the scope could be improved and the assumption that all transformers operate at 50% load is just wrong, but they are better than CSA C802.1 and as a general efficiency standard for transformers they are the best available.

2) Provincial regulations for transformer efficiency are problematic; a national regulation works much better. There are national, CSA, standards for transformers and manufacturers are aware of these and we will meet them even if they are not specified by a customer. Provincial regulations just aren't on the radar and unless a customer specifies them they are likely to be overlooked. Now, as I understand it, energy efficiency is a provincial rather than a federal responsibility so a "Canadian" standard for transformer energy efficiency may be difficult to achieve. The current CSA standards for liquid-filled C802.1 and C802.3 are made mandatory by including references to them in the CSA transformer standards, C2 series, C227 series, and C88. I think specifying energy efficiency probably exceeds the mandate of CSA but it was intentionally done this way to ensure the efficiency standards were followed.

A brief history of Canadian liquid-filled transformer efficiency standards (as I recall it) is:

- In the early 1990's Toronto area utilities developed a common standard for maximum losses for transformers purchased by contractors (not directly purchased by utilities), this resulted in the original CSA C802 series of standards.
- In the mid 1990's Ontario passed regulation making the C802 maximum losses mandatory; nobody knew. (I worked for an Ontario transformer manufacturer at the time, we didn't know the Ontario regulation existed.)
- In the late 1990's National Resources Canada (NRCan) proposed making C802.1 mandatory nationally.This put C802.1 on the radar. The CSA distribution transformer subcommittee, which basically includes representatives of provincially owned utilities and manufacturers, read C802.1 and realized that it wasn't appropriate nationally. The maximum losses specified were suitable for the Toronto area, where the load factor was high, but not for rural areas, where the load factor is low. The CSA distribution transformer subcommittee re-wrote C802.1 to specify minimum efficiencies at 50% load rather than maximum losses (which makes it more generally applicable and is the approach adopted by NEMA and later DOE).
- At this time NRCan wanted 3rd party verification of efficiency which would have added a fair bit of cost and time delay and was opposed by transformer manufactures and utilities. Manufacturers also discovered that NRCan only has the authority to regulate international or interprovincial trade so any NRCan regulation would not apply to transformers manufactured within the province they would be used, giving individual manufacturers a home province advantage. A compromise was reached in which NRCan dropped the 3rd party verification, making manufacturers and utilities happy, and in return the transformer subcommittee agreed to include a reference to C802.1 in the CSA C2 and C227 series of transformer standards making the efficiencies mandatory nationally, making NRCan happy and removing the home province advantage.
- In 2010 DOE efficiencies came into effect in the US and shortly thereafter there was a minor revision to CSA C802.1; C802.1-13 which basically modified the details of the efficiency calculation so it matched the method in DOE.
- In 2014 there was a proposal to revise C802.3, energy efficiency for power transformers, I believe this was a result of NRCan giving CSA some money with a view to make C802.3 mandatory. C802.3 had, in theory, been mandatory for many years in Ontario but was largely unknown. With the possibility of a mandatory national standard the CSA transformer committee dusted off C802.3-01 and updated it so that it specified minimum efficiencies rather than maximum losses and made those efficiencies consistent with C802.1 where applicable. The result was C802.3-15 which was made mandatory nationally by including it in a revision to CSA C88-16.

So, the DOE 2016 efficiencies are good, and are suitable for Ontario and the rest of Canada. But,I would also say that in my opinion, provincial transformer energy efficiency regulations work in theory but not in practice while federal regulations work in practice but not in theory.

[Original Comment ID: 210707]