TEST PROCEDURES FOR DISTRIBUTION TRANSFORMERS Supporting Statement 02 05 07REV3 PDF FILE

Supporting Statement for Paperwork Reduction Act Submissions
Test Procedures for Distribution Transformers
1. Explain the circumstances that make the collection of information necessary.
The Energy Policy Act of 2005 (P.L. 109-58) established minimum mandatory energy
conservation standards for certain distribution transformers – specifically, low-voltage
dry-type. While the energy conservation standards were codified by the Department on
October 18, 2005 (70 FR 60407) with an effectiveness date of January 1, 2007, the
Department did not yet have a test procedure in place by which manufacturers would test
and certify their low-voltage dry-type transformers as compliant with the regulations. On
April 27, 2006, the Department published its final rule on the test procedure for
distribution transformers. 71FR24972. With that final rule notice, the paperwork
requirements associated with testing these transformers for the purposes of demonstrating
compliance became effective.
The Department published a final rule notice establishing test procedures for measuring
the energy efficiency of distribution transformers, pursuant to sections 323(b)(10) and
346(a)(1) of the Energy Policy and Conservation Act. (42 U.S.C. 6293(b)(10) and
6317(a)(1)). It is under this authority that the Department is collecting information on the
efficiency of the transformers manufactured for sale into the U.S. market.
2. Indicate how, by whom, and for what purpose the information is to be used.
The information will be collected from approximately 57 manufacturers of distribution
transformers about 2 two times per year in order for the Department to ensure compliance
with the energy conservation standards in the Energy Policy Act of 2005 and the
Department of Energy’s Final Rule contained in Title 10 Code of Federal Regulations
Part 431. The information collection certification includes a listing of distribution
transformer designs and products of the various manufacturers. There are no forms
associated with this collection.
3. Describe whether, and to what extent, the collection of information involves the
use of automated, electronic, mechanical, or other technological collection
techniques or other forms of information technology.
It is expected that approximately 50% of the information collected will be received by
DOE electronically (via e-mail) and the remainder will be received via fax or through the
mail.
4. Describe efforts to identify duplication.
The reporting requirements in the certification report are such that within a family of
basic models, if a more efficient design is built than has already been reported to the
Department, the manufacturer does not need to report the efficiency or demonstrate
compliance in a filing to the Department. The manufacturer need only retain the

paperwork at their facility that records the measured efficiency, in the event of an
enforcement proceeding, so they would be able to demonstrate their compliance with the
regulation on all products shipped.
5. If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.
The collection does not have a significant impact on a substantial number of small
entities.
6. Describe the consequence to Federal program or policy activities if the collection
is not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.
If manufacturers do not comply with the periodic reporting requirement, there is a risk
that transformers would be sold into the market at efficiency levels below the mandatory
standards. This would have two detrimental effects: (1) it would distort the market,
rewarding any company that was violating the standard because their products would be
more cost-competitive than companies that were in compliance and (2) it would prevent
the nation from benefiting from cost-effective energy savings with each non-compliant
unit sold.
The Department is not aware of any technical or legal obstacles to reducing burden.
Many distribution transformer manufacturers regularly tested their products, as the
efficiency is one of the key properties that consumers of distribution transformers focus
on.
7. Explain any special circumstances that would cause an information collection to
be conducted in a manner inconsistent with OMB guidelines.
Certain manufacturers may be required to retain records for more than three years.
However, certain manufacturers may choose to certify the compliance of their
distribution transformers manufactured through the “Alternative Efficiency
Determination Method” or AEDM. This approach, in essence, enables the manufacturer
to validate their design software, which predicts the efficiency of the transformer, before
it is actually built. Once a sufficient number of designs are prepared, tested and the
software is validated, the manufacturer can product designs and does not have to conduct
further tests, they are able to file the efficiencies of their production runs as the predicted
efficiencies from the software.
As long as the transformer manufacturer elects to use the AEDM method to certify
compliance, they must retain records pertaining to the initial validation of the design and
testing software. These records would be vital to the Department’s standards
enforcement officers, should there ever be an enforcement proceeding against a
manufacturer who was using the AEDM. Thus, the AEDM validation records would

need to be retained for as long as the manufacturer chooses to use the AEDM as its
approach for representing compliant efficiencies to the Department.
8. If applicable, provide a copy and identify the date and page number of
publication in the Federal Register of the agency's notice, required by 5 CFR
1320.8(d), soliciting comments on the information collection prior to submission to
OMB. Summarize public comments received in response to that notice and describe
actions take. Specifically address comments received on cost and hour burden.
On April 27, 2006 the Department of Energy, Office of Energy Efficiency and
Renewable Energy; Energy Conservation Program published a Federal Register Notice
(71 FR 24844) for this proposed information collection. The Department did not receive
any comments in response to this notice.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There is no payment or gift to any respondents. They must comply with the requirements
of the regulations.
10. Describe any assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
There is no assurance of confidentiality, the data provided becomes part of the public
record and is subject to FOIA. Respondents are providing data to the Department to
demonstrate that the products they are selling are compliant with the national mandatory
regulations.
11. Provide additional justification for any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are
commonly considered private.
There are no questions of a sensitive nature in this collection of information.
12. Provide estimates of the hour burden of the collection of information. The
statement should indicate the number of respondents, frequency of response, annual
hour burden, and an explanation of how the burden was estimated.
There are approximately 57 respondents that will be required to respond to this collection
of information. There are 96 total burden hours total per company per year. This is
based on 56 hours of technician/technical work and 40 hours clerical work. The burden
hour total equals 57 respondents multiplied by 2 responses per/respondent (2 x 57 = 114)
multiplied by 96 hours hour per response. Total burden equals 57 x 2 x 96 = 10,944
burden hours.
13. Provide an estimate for the total annual cost burden to respondents or
recordkeepers resulting from the collection of information.

Capital costs – the Department understands that the efficiency of distribution
transformers is one of the core performance attributes that consumers look for when
purchasing a distribution transformer. Thus, the Department does not anticipate any
manufacturer in business today will need to purchase additional testing equipment to
measure or determine the efficiency of their distribution transformers. The Department
estimates that the total capital and start-up cost component would be approximately
$1,300 dollars per respondent. This reflects the costs of establishing a data storage area
for the retention of records documenting the compliance of their products with the
regulations. The total operation and maintenance and purchase of services component
costs are assumed to be zero, as once the reporting system is set-up, the measure of
efficiency and completion of the forms is routine, and is done already for products sold
that are as yet not covered by the regulation (and will be in the future). Therefore, the
Department has only an estimate of $1,300 dollars per respondent for capital costs for
setup. Total cost equals $1,300 multiplied by 57 respondents that totals $74,100.
14. Provide estimates of annualized costs to the Federal government.
The Department estimates that the annualized costs to the Federal government will be
approximately $10 thousand dollars. This is based on an expectation that reviewing the
submitted paperwork from 57 companies demonstrating compliance will consume
approximately 10 percent of a staff engineer’s time each year ($47.91 per hour).
15. Explain the reasons for any program changes or adjustments reported in Items
13 or 14 of the OMB Form 83-I.
All new collections are recorded as program changes. This is a new collection, so both
Items 13 and 14 record the burden as a program change.
16. For collections of information whose results will be published, outline plans for
tabulation and publication.
This data will not be published.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
The Department is not seeking approval to not display the OMB expiration date.
18. Explain each exception to the certification statement identified in Item 19,
"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
There are no exceptions.