### 1 COMMENTS ON THE GLOBAL SUPPLY OF GRAIN ORIENTED ELECTRICAL STEELS 1. BACKGROUND As t he efficiency standard implemented in 2010 increased the use of low loss core materials , a higher standard will drive transformer s towards even lower design inductions ( re quiring more core material per kVA output ) and /or still lower loss core materials such as M2, ZDMH or Amorphous Metal. As a result, t wo questions were raised during subcommittee discussions concerning : (i) T he ability of core materials manufacturers to suppl y “ capable ” products in sufficient volumes to meet demand

. (ii) Identifying an efficiency standard level that would be conducive to a well - supplied and competitively priced market place for core materials

. AK Steel was asked to provide comment on both matters. Th e following comment is a summary of public information on the capabilities of present GOES manufacturers . I t should be noted that the information summarized in Table 1 regarding “ product capability ” and “ production capacity ” represent AK Steel’s best est imate as we lack specific information about our competitors’ production mix that would be needed for certainty

. 2. COMMENT S ON HIGH PERMEABILITY STEELS There are three “general classes” of high permeability core material: (i) Products for stacked core transfo rmers 1

– NOPR references to “H - 0” and “H - 0 DR” both refer to AK Steel’s domain controlled (laser scribed) high permeability 9 - mil product. AK Steel is the only domestic supplier of high permeability GOES products at this time . S imilar products are supplied by other large volume global suppliers such as Nippon Steel, JFE Steel and TKES with o ther manufacturers supply ing lesser volumes

. The OPS study evaluated AK Steel’s 9 - mil H - 0 CARLITE® DR® product

. (ii) Products for wound - & - annealed core transformers

– NOPR re ferences to “ZDMH” refer to a domain controlled high permeability GOES product intended for wound - & - annealed core transformers . These products are supplied by two Japanese steel makers , Nippon Steel Corporation and JFE Steel Corporation , under the trade nam es “ZDMH” and “JGSD”, respectively , as 9 - mil and 11 - mil product s (Appendix A). We are uncertain which 9 - mil grade (23ZDMH80 or 23ZDMH85) was evaluated by OPS

. (iii) Non - domain controlled products

– the NOPR did not include M - 0H in the analysis but these steels a re widely used in stacked and wound - & - annealed core transformers. The specific grade of interest would be a 9 - mil M - 0H type (equivalent to AK Steel H - 0 CARLITE). Stacked core power transformer manufacturer s are the largest users of high permeability steel s. As ultra high - voltage power transformers are often “size - limited” , high permeability steels offer significant value added owing to much superior “kVA output per pound of transformer” and significantly reduced noise performance (transformer hum). V irtual ly all of AK Steel’s shipments of 9 - mil H - 0 , 11 - mil H - 1 and 12 - mil H - 2 CARLITE and CARLITE DR go in to this segment. Moreover, AK Steel’s present production capacity for H - 0 CARLITE and H - 0 CARLITE DR is fully committed ( i.e., sold o ut) for the foreseeable future. The power transformer market is robust for two main reasons: (i) G rowing demand in the Developing World ; and , (ii) R eplacement demand in the Developed World (mainly US, Canada and Europe). As a result, high permeability steels are in high demand worldwi de. It should be noted that wound - & - annealed core transformers are peculiar to specific regions of the global market (mainly USA, Canada, Mexico, Japan and Taiwan; secondarily, India) . These transformer design s represent a small segment , about 5 - 10%, of t he global transformer market

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1 See Appendix A (AK Steel, Nippon Steel and JFE Steel product specifications for domain controlled high permeability products).

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3. AVAILABILITY BY GRADE TYPE Given t he charge from the working group to identify the standard level that is conducive to a well - supplied and competitively priced marke tplace for core material buyers , we offer the followin g comments M2

– M2 is a 7 - mil product produced only in the USA by AK Steel and ATI

. AK Steel’s process requires a more precise (narrower range) in melt chemistry for M2 than M3 requires

. M3/M - 0H 2

– M3/M - 0H are 9 - mil products (M3 is a conventional type ; M - 0H is a high permeability type) which are functionally interchangeable in most distribution transformer designs. These are the most widely available high grade GOES products with a large global production base. In the USA, AK Steel and ATI both have ample M3 manufacturing capability and capacity . This is complemented by M3/M - 0H capable large - volume suppliers like Nippon Steel, JFE Steel and TKES and smaller - volume capable producers includ ing StalProdukt (PL), Cogent (UK) and Aperam (BR). We anticipate that large - volume suppliers NLMK (RU), Wuhan Steel (CN) and Baosteel (CN) will develop M3/M - 0H capability in the future

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“ H - 0 DR ”

– H - 0 DR is a domain controlled high permeability product for use in stacked core transformers. AK Steel is the only domestic su pplier of laser scribed high permeability GOES products at this time. Similar products are available from other capable large - volume suppliers such as Nippon Steel, JFE Steel and TKES. Other manufacturers make lesser amounts but their production is expecte d to grow rapidly.

“ ZDMH ”

– Japanese supply capacit y is unknown. AK Steel positioned M2 LITE CARLITE® for this segment and has proprietary information showing that M2 - LC performs comparably to ZDMH in most wound - & - annealed core transformer designs. 4. GOES CAPACITY/CAPABILITY Table I summarizes the capability and total (all types combined) capacity for the established producers.

For the 2011 - 2014 timeframe, we estimate GOES production capacity at about 2.7MM mt/yr. We estimate that 2011 global demand is about 2.1 - 2.2MM tpy, resulting in significant unused capacity from expansion projects started when pre - recession GOES demand was very high.

2 The “M - 0H” designation does not exclusively define a 9 - mil product (see last page of the JFE product information).

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5. COMMENT S ON AMORPHOUS METALS At this time, there are two established manufacturers of amorphous me tal strip . Information about the Hitachi Metals Group and its US subsidiary, Metglas Inc., is well known. Appendix II contains information from the web site of Advanced Technology & Materials (AT&M) Company. Ltd., of China. AT&M supplies about 40,000 mt/yr of amorphous strip, including magnetic grades which are sold under the trade name Antaimo® for use in transformers. AM&T also produces nanocrystalline magnetic materials which are sold under the name Antaimano®. Appendix II provides a brief history of AT&M ( page 1 ) . AT&M was established as a Chinese government enterprise in 1998 with a substantial technical staff cited (4 th paragraph on page 1) and links to Chinese state engineering enterprises

. Based on product information on the AT&M web site , the y prod uce Antaimo as cast strip in widths of 64 and 100 mm (2 1⁄2 and 4 inches) as shown under “specifications” section (Appendix II page 2). The specific amount of Antaimo being supplied is not stated but applications cited on the AT&M product information are cite use as small (narrow width ) high frequency transformer power cores. 6. RECOMMENDATION S DL - 1 to DL - 5 : Given that M2 and ZDMH are “limited availability products ” with only three or four suppliers worldwide , we believe that GOES manufacturers would concu r with AK Steel’s view that any enhanced standard be based on M3 /M - 0H

. DL - 9 to DL - 13 : Given that the supply of M3 /M - 0H would be largely consumed for DL - 1 to DL - 5 transformers , we believe that GOES manufacturers would concur with our view that an enhanced standard should be based on M4 to ensure that core material s would be wide ly available.

Submitted by: Jerry W. Schoen Principal Engineer Research & Technical Services AK Steel Corporation 705 Curtis Street Middletown, OH 45043 - 0001 USA