October 2004

Amendment to Canada's Energy Efficiency Regulations

DRY-TYPE TRANSFORMERS

The Office of Energy Efficiency (OEE) of Natural Resources Canada (NRCan) has amended Canada's Energy Efficiency Regulations (the Regulations) to require Canadian dealers to comply with minimum energy performance standards for dry-type transformers imported or shipped interprovincially for sale or lease in Canada.

Amendment 6 to Canada's Energy Efficiency Regulations was published on April 23, 2003. The regulation of dry-type transformers is included in this amendment with a completion date of January 1, 2005. This requires all dry-type transformers, as defined in this document, manufactured after this date to meet the minimum efficiency performance standards.

NRCan is concerned about the energy efficiency of transformers available in the marketplace. Economic analyses have shown that there are substantial energy savings to be achieved by regulating minimum efficiency levels. The regulation of dry-type transformers will significantly contribute to the reduction of carbon dioxide and other atmospheric emissions.

This bulletin attempts to put the requirements of the amendment in simpler terms. However, the legal text of the amendment, as found in the Canada Gazette Part II, is the official document.

BACKGROUND

In June 1997, NRCan distributed a bulletin which contained proposed regulations for transformers. NRCan conducted several consultation workshops in November 1997, June 1998, October 1999 and February 2001 (bulletin in December 2000) to receive comments on these proposed regulations.

Issues identified at the workshops included the transformers to be regulated (and excluded), the proposed energy efficiency standards and the economic analysis. Also of interest was harmonization with other Canadian (provincial) standards and the voluntary standard National Electrical Manufacturers Association (NEMA) TP 1-1996, Guide for Determining Energy Efficiency for Distribution Transformers and associated document TP 2-1998, Standard Test Method for Measuring the Energy Consumption of Distribution Transformers, in the U.S.

The amendment was pre- published in the Canada Gazette Part I on December 14, 2002, the only comment received was a suggestion that the completion date for dry-type transformers could be earlier than January 1, 2005. This viewpoint had been raised during consultations used to develop the regulations. NRCan concluded that the original date was the most appropriate for the majority of stakeholders.

PRODUCT DESCRIPTION

The Regulations apply to single- and three-phase, 60 Hz, dry-type transformers with a primary voltage of 35 kV and below and a secondary voltage of 600 volts and below, rated 15 to 833 kVA for single-phase and 15 to 7500 kVA for three-phase.

Products specifically excluded from this regulation include:

• Autotransformers
  
  
• Drive isolation transformers
  
  
• Instrument transformers
  
  
• Rectifier and converter transformers
  
  
• Sealed and transformers
  
  
• Testing transformers
  
  
• Transformers with tap ranges greater than 10% (includes furnace transformers)
  
  
• Welding transformers.
  
  

ENERGY EFFICIENCY STANDARDS

The dry-type transformer energy efficiency standards are as found in CSA-C802.2-00, Table 1.

The reference winding temperature is 75°C.

ENERGY PERFORMANCE TEST PROCEDURE

The Canadian Standards Association standard CAN/CSA-C802.2-00, Minimum Efficiency Values for Dry-Type Transformers, is the test procedure for transformers under regulation as described in this document.

The standard can be ordered from:

EFFECTIVE DATE

NRCan is giving notice that these energy efficiency standards for transformers come into effect on January 1, 2005.

ECONOMIC ANALYSIS

There has been no change to the economic analysis for dry-type transformers.

NRCan employed benefit-cost analysis to determine the economic attractiveness of improving the energy efficiency of dry-type transformers. The net present value, calculated by subtracting the present value of incremental costs from the present value of incremental benefits, over the useful life of the product, was chosen as the indicator of economic attractiveness. The Base Case analysis used a 7 percent social discount rate, as prescribed by the Government of Canada Treasury Board, and Canada average industrial electricity prices, based on NRCan's official energy supply demand forecast (Canada's Energy Outlook 1992-2020: Update 1996). Sensitivity analyses were conducted around the discount rate (5 and 10 percent) and energy prices (high and low industrial electricity prices).

The economic analysis showed positive net benefits for the Base Case and all sensitivity scenarios for dry-type transformers. This finding supports the case for regulated minimum energy efficiency levels for dry-type transformers.

The industry representatives have indicated agreement with the market information and analysis presented at the previous workshops.

VERIFICATION REQUIREMENTS

The same verification requirements that applied to other products regulated under the Energy Efficiency Act will apply to dry-type transformers.

NRCan is proposing that regulated transformers will 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. This organization must also be recognized by NRCan. 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 industry representatives have indicated agreement with the verification requirements presented at the previous workshops.

REPORTING REQUIREMENTS

The energy efficiency report (as per section 5 of Canada's Energy Efficiency Act) required for this product will include the following information:

• the product name (i.e. Dry-Type Transformer)
  
  
• the manufacturer
  
  
• the brand name (i.e. model name)
  
  
• the model number
  
  
• the kVA rating
  
  
• the name of the organization or province that carried out the verification and authorized the verification mark that will appear on the product
  
  
• single- or three-phase
  
  
• the voltage (high and low), and
  
  
• the % efficiency
  
  
• load and no load losses
  
  

This 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.

IMPORTING REQUIREMENTS

A dealer who is importing these products into Canada must include the following information on the customs release document:

• the product name (i.e. Dry-type Transformer)
  
  
• the model number
  
  
• the brand name, if applicable
  
  
• the name and address of the dealer importing the product, and
  
  
• the purpose for which the product is being imported (i.e. for sale or lease in Canada without modification; for sale or lease in Canada after modification to comply with energy efficiency standards; or for use as a component in a product being exported from Canada)
  
  

ISSUES

ENERGY STAR^®

ENERGY STAR labelled products are being actively promoted in Canada. NRCan will be participating in a variety of marketing strategies that will be promoting the use of ENERGY STAR qualified transformers in the Canadian Market. These are still under development and we welcome input on how we structure these initiatives. Some Canadian manufacturers have already signed participant agreements with NRCan.

Liquid Filled Transformers

Manufacturers and purchasers of liquid filled transformers (through the Canadian Electricity Association - CEA) are collecting and publishing data demonstrating the industry's compliance with CSA C802.1. The results are published in the CEA's Environmental Commitment Report starting in 2001.

Model Number

It is essential that the product name and model number used on the import documents correspond to those used in the initial report to ensure compliance to the regulations by providing a link between the documents.

NRCan has proposed a redefinition the definition of "Model Number" in the regulations.
"model number" means, in respect of any model of an energy-using product other than a motor, the designator that is assigned to that model for the purposes of these Regulations and that distinguishes it from similar models

This allows the manufacturers and NRCan to agree upon a designator, not necessarily the model number used by the manufacturers. NRCan will work with manufacturers and dealers to identify the designators to ensure compliance with the regulations. This new definition does not impact the Unique Motor Identifier (UMI) for Motors.

Rewound Transformers

Rewound or rebuilt transformers will not be covered by this regulation. NRCan will be undertaking to monitor the situation to determine if the rewound market is growing at the expense of compliant transformers. A similar concern was raised during the motor consultations prior to regulation in 1997. An April 2002 report, looking at the impact of the regulations on the Motor market, has shown a reduction in motor rewinds as the replace / repair decision is leaning towards replacement. The potential loophole did not materialize.

Harmonization

A major consideration in developing all regulations is harmonization with other regulatory authorities. This avoids placing undue competitive pressure on manufacturers and purchasers. The test standard for NRCan's proposed regulation is CSA C802.2. This document uses as a basis the voluntary standard issued by the National Electrical Manufacturers Association (NEMA) in the US. NEMA Standard TP-2 is referred to for Test Accuracy (section 2), Resistance Measurements (Section 3) and Loss Measurements (Section 4). The minimum efficiency levels correspond with NEMA TP-1.

Dry type transformers have been incorporated into Ontario Regulations, referencing C802.2, with an effective date of April 2003. New Brunswick has updated their legislation to include dry-type transformers. Other Provinces have not indicated how they will proceed.

There are strong indications that TP-1 and TP-2 will influence the USDOE's rulemaking process. NRCan is closely following the progress that DOE is making in their rulemaking and exchanging information where possible. The timetable for rulemaking is such that it is unlikely that the US will have effective minimum standards prior to 2007. NRCan is prepared to move towards harmonization with any US levels that are determined if they differ from those proposed here.

The following US states have, or will soon have, requirements that reference NEMA TP-1; Massachusetts, Minnesota, Wisconsin, New York, Vermont, California and Oregon.

COMMENTS INVITED

All correspondence should be forwarded to: