Eurelectric - EU Proposals of 20/3/2012 on implementing Directive 2009/125/EC with regard to small distribution and power transformers
Eurelectric agrees that it is in the best interests of society if all utilities and private industry ensure that losses on any plant used is limited to an economic and sustainable level.
However while supportive of the spirit of this proposal, Eurelectric are deeply concerned that its specific contents in terms of prescribed, uniform minimum loss levels are not sufficiently justified from a technical or economic standpoint, and preclude:- the application of engineering skill and expertise on the part of utilities in delivering the overall lowest level of losses throughout the system, that of manufacturers in developing transformers which balance different characteristics to deliver the best overall performance and
- the input of regulators in ensuring that social risk is reduced and the best value is delivered for society.
Most European Utilities have incorporated the value of losses into all aspects of Network Investment for more than thirty years.Every transformer, cable and line is sized and bought to optimise losses, and in every modification of the overall network, several options are considered with the capitalized value of losses included in each, so that the overall best value for the customer is obtained.
Eurelectric feel that a single low value of losses applied throughout EU will result in non-optimal results, and that a better approach would be to have a minimum value of efficiency/maximum value of Iron/Copper losses, and to allow the utilities to optimise the actual results through the use of Capitalization rates in a TCO approach.
The results of the analysis by VITO were sufficient to show that the use of more energy efficient transformers could be justified where the value of the energy saved was greater than the costs incurred, but was not sufficiently sophisticated to justify the levels of losses proposed in the EU Draft Proposals on either a Technical or Economic level.
In particular, below a certain level of losses, the actual optimum level depends on the circumstances pertaining in that particular utility as to how the transformer is used, the local price of electricity and the appropriate discount rate for that country.
A Directive prescribing specific low levels of losses would result in cumulative costs to EU utilities of several hundred million euro, thus the justification required is quite onerous . However the required justification for meeting this standard has not been provided.
In contrast, a minimum level of losses such as CkBk could probably be justified more easily, and such levels would still allow utilities to optimise through use of Capitalization rates and Total Cost of Ownership, to the appropriate lower value of losses for that utility ( - per SEEDT report BkA0 was common in Northern Europe, and a random sample of UK, Ireland and Austria suggested existing values below CkBk).
Eurelectric response covers:- Overview of limitations in current draft and alternative proposals to overcome these using a combination of Minimum Efficiency and Capitalization rates for Iron and Copper Losses
- Comments on the document of 20/3/2012 ‘Working document on a possible Commission regulation implementing Directive 2009/125/EC with regard to small Distribution and power transformers.
- Comments on points raised in the meeting of 20/4/201