Proposed Amendment to Canada's Energy Efficiency Regulations for Dry-type Transformers

BULLETIN
October, 2005

The Office of Energy Efficiency of Natural Resources Canada (NRCan) is proposing to amend Canada's Energy Efficiency Regulations (the Regulations) to delete from the definition of dry type transformers some of the exemptions that are contained therein.

Dry-type transformers were added to Canada's Energy Efficiency Regulations on April 23, 2003 with an effective date of January 1, 2005. Upon implementation, manufacturers have made NRCan aware that there were some loopholes in the Regulations that would allow lower-cost, exempt transformers to compete unfairly with transformers that comply with the Regulations. Consequently, NRCan proposes to amend the Regulations in order to eliminate some of the exemptions.

This bulletin attempts to put the proposed revisions of the amendment in plain language. The legal text of the amendment will be pre-published in the Canada Gazette Part I.

BACKGROUND

When Canada's Energy Efficiency Regulations for dry-type transformers came into effect, NRCan was approached by manufacturers who commented that the 10% tap range provided a loophole that needed to be closed off.

NRCan proposed that the tap range be eliminated completely, and on 2 June 2005 held a workshop in Montreal to discuss the issue with the manufacturers and other stakeholders. At the workshop, all the manufacturers agreed that the tap range exemption could be eliminated. The manufacturers also discussed and agreed to several other changes in the exemptions.

DESCRIPTION OF CHANGES

As a result of commentary received from transformer manufacturers, and analysis conducted by the department, NRCan is proposing to revise the definition of dry-type transformers as per the following:

• The tap range exemption is being eliminated.
  Rationale: Elimination of the tap range exemption is based on the possibility of lower-cost exempt designs competing unfairly with efficient designs
• Drive (isolation) transformers with a single output winding will be included in the regulations, provided the low-voltage line current is 1500 A or less.
  Rationale: This closes a loophole whereby a drive transformer could be bought by a distributor and sold as a regular transformer
• Non-ventilated transformers will be exempt from the regulations.
  Rationale: This clarifies that non-ventilated transformers are not the same as sealed transformers, and should also be exempt
• Furnace transformers will be exempt from the regulations.
  Rationale: Previously, furnace transformers were exempt by implication, but it was not explicitly stated in the regulations
• Previously, only transformers with a secondary voltage of 600 Volts or less were included in the regulations. Now, transformers will be included regardless of their secondary voltage.
  Rationale: This eliminates a loophole that inadvertently exempted 3750-7500 kVA transformers
• Transformers having a low-voltage line current larger that 4000 A will be exempt from the regulations.
  Rationale: To meet the regulations, these transformers would need to be designed with a bigger core size and many other design challenges. In many cases it could be impossible to meet the efficiency levels

TEST METHOD AND ENERGY EFFICIENCY LEVELS

Although the Canadian Standards Association is currently revising the C802.2 dry-type transformer standard, the test method and energy efficiency levels in the regulations will continue to be those in CSA standard C802.2-00.

EFFECTIVE DATE

The regulations will become effective as of the registration of the regulation, which we anticipate at this time to be April 2006.

VOLUNTARY COMPLIANCE WITH THE REGULATIONS

At the June transformer workshop in Montreal, the idea was raised of a formal commitment by the manufacturers to build only compliant products until the revised regulations come into effect. This idea was widely supported at the meeting. As of October 31, 2005, Atlas Transformer, Delta Group, Marcus Transformer of Canada, and Rex Power Magnetics have communicated their commitment.

VERIFICATION AND REPORTING

Firms must ensure that reporting and verification procedures are in place.

The verification requirements remain unchanged. Regulated transformers must carry a verification mark indicating that the energy performance of the product has been verified. The verification mark is the mark of a Standards Council of Canada accredited certification organization that administers an energy performance verification program for this product. NRCan must also recognize this organization. NRCan will also accept labels issued by a province indicating that the product meets the provincial energy efficiency levels as a verification mark, providing that the provincial level is equivalent to or exceeds the federally regulated level.

The reporting requirements remain unchanged. An energy efficiency report must be submitted, by the dealer, to the Minister of NRCan before the product is imported into Canada or traded interprovincially for the first time.

COMMENTS INVITED

The purpose of this bulletin to provide stakeholders with a concise interpretation of the proposed amendment, as they apply to dry-type transformers. The full legal text will be as pre-published in the Canada Gazette Part I, which will amend the official regulations once published in the Canada Gazette Part II.

Comments are invited during the 75 day comment period (between pre-publication and publication) and should be forwarded to: