Ecodesign for small and medium power transformers – EDSO views on European Commission working document
EDSO for Smart Grids believes that the draft Directive text regarding the small and medium power transformers and designed to implement Directive 2009/125/EC (ecodesign requirements for energy-related products), will have severe implications, forcing the main stakeholders – small and medium size industries, small generation operators, electrical utilities – into unjustified and large investments, increasing the costs for customers without producing the intended benefits.
- The main parameters used for investments validation – discount rate, duration of the investment and price of electricity – are questionable. Some of the parameters have been overestimated in the same direction, validating the convenience of very efficient transformers, why also the results are overestimated.
- The proposed efficiency levels require transformers much larger in size and heavier than the existing ones. As a result, present and existing box installations are generally not suitable for the new proposed transformers and also the pole mounted transformers would require several arrangements with a considerable cost increase.
- In case of an outage or fault of an existing transformer the substitution with a new one would require more sophisticated modifications of the installation and more time. This could make it difficult to keep the present high level of quality of the service to the customers.