Curse of Dual Certification for Distribution Transformers
There is a conflict, the manufacturers are requesting Govt. of India to allow them the compliance of one of the authorities/ agencies directive i.e. BIS or BEE for the same goal of producing Energy Efficient DTs, and should not insist upon as in both the cases, they have to manufacture Energy Efficient Distribution Transformers as per only one standard IS:1180 Part 1/2014…
- B Lal
After the enactment of Energy conservation Act 2001, BEE was charged with the prime responsibility of efficient use of energy in variety of equipment particularly in the house hold appliances in a bid to save electricity as per saying that a unit of KWH saved is unit generated. This is of course, true for any equipment being operated on electrical energy. The efficiency, performance and conservation of energy depend upon quantum of energy losses in the equipment. By reducing the losses, the efficiency can be improved which is the main concern of BEE.
Consequently a notification dated February 2009 was issued by Ministry of Power specifying the energy consumption standard under S&L programme describing energy losses at 50% & 100 % loading of DTs up to 200 KVA rating units at 11KV level and labeled as star 1 to star 5 having progressively maximum to minimum losses respectively.
Recently, BEE has issued an amendment to its February 2009 notification as per No. SO.4062 (E) dated 16th December 2016 effective from 1st January 2017 which, has been recommended for extension by another 6 months wherein the losses of Distribution Transformers (DTs) has further been reduced thereby assigning its original star 4 (four) as star 1 (one)and star 5 (five) as Star 2 (two) with further new losses for Star 3,4 & 5 worked out by extrapolating. The transformer manufacturers are already producing and supplying new Star 1 (one) transformer as per the requirement of the purchasers.
The efficiency of any equipment i.e. say Distribution Transformer can be worked out as output in KW divided by sum of output and losses at a specified load and temperature. For energy efficient transformer design, superior grade active core material and copper winding are necessary to get the lower losses, greater reliability and reduced heat output i.e. less carbon emission. Lower losses are most suitable from the point of techno-economical electrical distribution system. The maximum efficiency of Distribution Transformer is when no load losses are equal to the load losses which is not at all adoptable economically. In a rough calculation of 100 KVA Distribution Transformer, the efficiency at 100%, 75%, 50% & 25% loadings at unity power factor at fixed no load losses varies between 98.0% to 98.5 % but with power factor of 0.8 the efficiency is again affected by about 0.20% which can be exactly computed by the designer of the transformer. Incidentally, in contrast the efficiency of power transformer rather large power transformer, the efficiency level is very as high as 99.75% as the designer has to keep the fixed losses of core and variable load losses in optimum ratio generally between 1: 3 to 5 and lower the ratio the most economical operation of the power transformer can be obtained. The designer has to consider such aspects based on the given technical specification and operational duties the unit has to perform during its life time.
It is very well known that 95% of the distribution segment is controlled by State Governments Discoms / Utilities and Electricity Boards, where political interference is not ruled out and is responsible for lot of ills of distribution companies. One of the major concern of the authorities was very high failure rate of Distribution Transformers since the turn of the country. Inefficient and bad quality of Distribution Transformers cause 4 to 5 % of losses in the distribution network. In this connection CEA, the Apex organisation of Ministry of Power in consultation with experts of transformer manufacturers worked out detailed technical document and issued guidelines for specification of energy efficient outdoor type three phase and single phase distribution transformers in 2008 specifying all technical parameter of losses including at 50% and 100% loading, raw material, insulation level, testing, inspection, manufacturing, procurement and installation etc. to be followed by all Discoms/Utilities at National Level, even when the prevalent IS:1180 /1989 did not specify the losses in the standard. In fact all Discoms/Utilities were specifying their own set of losses at no load and full load and the other parameters while issuing tenders for procurement of transformers.
Accordingly all the transformer manufacturers dutifully started implementing the mandatory BEE’s S&L programme to produce star 1 to 5 energy efficient DT s for the power sector after completing the necessary formalities of BEEs regulation and obtaining certification for labeling the DT star 1 to star 5.
Concurrently CEA in its notification dated August 2010 issued technical standard for construction of electrical plant and electric lines regulation for Distribution Transformers that:“The maximum losses of oil filled DTs shall not exceed as that for at least 3 star transformer specified by BEE wherever applicable.”
Till 2009 the Distribution Transformers were being manufactured and used as per specification of IS:1180/1989 which was under revision for the last number of years and was finally notified in 2014 as IS:1180/2014 (part-2) after 15 years under 4th revision encompassing losses for 50% & 100% up to 2500 KVA rating at 11/22/33 KV as level 1, 2 &3 equivalent to BEEs star 3,4, &5 thereby necessitating amendment of CEAs technical standard for construction of electrical plant and electric lines through notification in 2015 as under:
“The maximum losses of oil filled DTs shall be as per relevant Indian Standard i.e. IS: 1180 /2014 (2014)”
It may be noted the quality of any product is a prime concern even at the highest level of Hon’ble P M who had declared a slogan ‘Zero defect, Zero effect’ and implored on the industries not to compromise on product and environment in his address to the Nation from the rampart of Red Fort on 15th August 2014 the Independence Day. Such like pronouncements were repeated by others including Cabinet Secretary in International industrial fathering for attracting foreign investments coupled with lot of incentives for doing business with ease under ‘Make in India’ schemes which in fact is pet subject of our Hon’ble P M.
Even Ministry of Heavy Industries and Public Enterprises (DHI) issued a quality control order on Electrical Transformer in 2014 for manufacture/use of DTs in accordance with IS:1180/1989 up to 100 KVA rating at 11 KV level which was subsequently amended in 2015 mandating the manufacture/sale & use up 2500KVA at 11/22/33/ KV as per revised IS:1180 Part 1/2014 effective from 1st February 2016 duly BIS marked only.
It will be thus observed that the manufacturers of DTs have to obtain dual certification from BEE & BIS for energy efficient DTs under IS:1180 Part 1/2014.
Now there is a conflict, the manufacturers are requesting Govt. of India to allow them the compliance of one of the `authorities/ agencies directive i.e. BIS or BEE for the same goal of producing Energy Efficient DTs, and should not insist upon as in both the cases, they have to manufacture Energy Efficient Distribution Transformers as per only one standard IS:1180 Part 1/2014. But Ministry of Power has shown its helplessness as in both cases it is mandatory through Gazette Notifications, which obviously is not desirable as manufacturer has to observe and complete, all the formalities/ requirements of both the agencies which not only create hindrance in conducting the business with ease but also involves lot of time and expenditure of yearly renewal of license and hefty BEE’s labeling/BIS marking fees of each types of distribution transformer produced. Besides the suggestion shall save the administrative work of one of the Govt. Agencies. ITMA has requested to PMO to intervene, vide its letter No. ITMA/11/2016 dated 13th October 2016.
The PMO has forwarded the representation to MoP who has given stock reply that the matter has already been decided by Hon’ble Union Power Minister indirectly intimating that the transformer manufacturers shall have to comply with the requirements of both the agencies with slight concession which is insignificant and of no consequence.
The transformer manufacturers are not satisfied and again made representation to Hon’ble Union Power Minister to re-examine the issue and appreciate all the aspects dispassionately in order to give relief to the stakeholders, so that they are able to do the business with ease which slogan is hallmark of the present day Govt. of India and finds special mention in the current budget.
In the representation the following point have been stressed/highlighted for rendering justice to the transformer industry at National Level.
1. The DTs have to be manufactured, supplied and purchased only as per IS 1180 Part 1/2014, for BIS & BEE.
2. In fact BEE follows all the testing procedures as laid down by BIS in their standards.
3. All the testing procedures to be followed for taking certification for any size/rating from BEE and BIS are the same.
4. BEE having only one central office in Delhi is controlling whole Indian Transformer Industry, whereas BIS has got its own Regional and Zonal offices across India thus leading to a more efficient working.
5. BEE Charges Rs 100/- per transformer irrespective of size of the same. BIS Charges Rs 3 per KVA per job. e.g. for a 16 KVA Job BEE would take Rs 100/- per job and BIS would take 16 KVA x Rs3 = Rs 48/- per job and on the contrary for a 200 KVA Job BEE would still take Rs 100/- but whereas BIS would take 200 KVA x Rs3 = Rs600/- per job. This double marking fee is ultimately a burden on State Utilities or private customers.
6. Till 31.12.2016 scope of BEE was limited from 16 KVA to 200 KVA 11 KV Class Transformers and BIS up to from 6.3 KVA to 2500 KVA 11, 22 & 33 KV Class including single phase transformers as well. Since 01.01.2017 scope of BEE has been raised from 16 KVA to 2500 KVA 11 KV Class Transformers. BIS has much wider scope as compared to BEE.
7. Till 31.12.2016 Transformer Losses of BEE 3 Star, 4 Star & 5 Star Transformers were equivalent to those of Level 1, Level 2 & Level 3 Transformers as per BIS respectively.
8. From 01.01.2017 as per new table in notification Dt 16.12.2016 of BEE, 1 Star and 2 Star transformers losses now stand equal to the losses of Level 2 & Level 3 Transformers as per BIS.
9. BEE is only concerned with end results of transformer like losses whereas for a transformer to be certified by BIS the manufacturer has to take care of all the raw materials also which need to be of a particular standard or BIS certified as defined by BIS.
It would be appreciated from the above comparison of requirements between BIS & BEE ultimate rigmarole of BIS is the main nucleus which takes care of BEE as well. As such one agency which enforces rigorous requirements should be opted.
It has been emphasised time and again that BEE’s star labeling programme is generally for household items which helps in awareness of consumers before purchase of energy efficient electrical appliances/equipment from the open market as the consumer has no means to check the quality/ efficiency of the product and therefore he could mainly rely on the star label provided by manufacturer on the basis of BEE's certification. Whereas the DTs are not a consumer item but a capital goods item being procured/used by the Govt. utilities/discoms and EPC contractors as per the approved technical specifications contained in tender documents as per IS:1180 Part 1/ 2014 and are supplied by the manufacturers only after inspection and testing of the transformer at the works of the manufacturer which are also being tested separately at the BIS recognised Test Laboratories before supply. It is prudent to note that one equipment i.e. DT is required to be manufactured as per IS: 1180 Part 1/2014 but has to be certified by two agencies i.e. BEE and BIS for the same goal for providing Energy Efficient DTs as per the notifications in vogue.
In view of the forgoing you are again requested to look into the matter and consider the applicability of only one of the agencies for mandatory certification of DTs for manufacture and supply of quality energy efficient DTs as per IS:1180 Part 1/2014 which will afford the manufacturers to deal with only one agency for doing the business with ease. Besides this will further have following benefits and thus will reduce wastage of time and money.
i. To save establishment charges of one of the Department of Govt. of India.
ii. To save the drill of transformer manufacturers staff to attend to the requirements of BEE & BIS.
iii. To save additional expenditure of transformer manufacturers by way of registration fee, marking/labeling fee for each unit of transformer produced/manufactured.
iv. To save the transformer manufacturer from carrying out drill of getting renewal of registration separately with BIS & BEE by incurring hefty fee.
In the end, the Ministry of Power is requested to re-consider to do justice in order to mitigate the hardship and harassment of the transformer industry.
Indian Transformer Manufacturers Association (ITMA) Ghaziabad
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