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UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY 

MEETING of the MV WORKING GROUP

Volume II

American Public Power Association

1875 Connecticut Ave., NW

12th

Washington, D.C. 20009

Floor

Thursday

 December 1, 2011

Facilitator:

Richard Parker

University of Connecticut Law School

Host:

American Public Power Association

1875 Connecticut Ave., NW

12th

Washington, D.C. 20009

Floor
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Participants Identified: 

Gene Andert

REA Magnet Wire

Rick Anderson

Fayetteville Public Works Commission

Tim Ballo

Earth Justice

1625 Massachusetts Avenue

Suite 702

Washington, DC 20036

Scott Beck

Lakeview Metals

Robert Berman

Berman Economics

1915 Orchid Court

Vienna, VA 22187

Chris Brown

Cogent Power

John Caskey 

National Electrical Manufacturers Association

Greg Coulter

Consultant 

Prolec GE

Jim Creevy

National Electrical Manufacturers Association

1300 North 17th

Suite 1752

Street

Rosslyn, VA 22209

Andrew deLaski

ASAP

20 Belgrade Ave, Suite 1

Boston, MA 02131

Marianne DiMascio

American Standards Awareness Project
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Tom Eckman

Northwest Power and Conservation Council

Gary Fernstrom

Pacific Gas & Electric Company

13055 Parkhurst Dr

Oakland, CA 94619

Chuck Foster

Edison Electric Institute

Carlos Gaytan

Prolec GE

Robert Greeson

Federal Pacific Company

Bruce Hirsch

Baltimore Gas and Electric, EEI

Gerald Hodge

Howard Industries

PO Box 1586 

Laurel, MS 39441

Phil Hopkinson

HVolt, Inc.

Michael Hyland

American Public Power Association

Dave Millure

Metglas Incorporated

440 Allied Drive

Conway, SC 29526

Steve Nadel

American Council for an Energy-Efficient Economy

Wes Patterson

ABB, Inc.

Eric Petersen 

AK Steel
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Ray Polinski 

Allegheny Ludlum - ATI

James Rakowski

ATI Allegheny Ludlum

Steven Rosenstock

Edison Electric Institute

701 Pennsylvania Avenue NW

Washington, DC 20004-2696

Robin Roy

Natural Resources Defense Council

1200 New York Avenue, NW, Suite 400

Washington, DC 20005

Paul Ryan

Hitachi Metals America

800 Grand Avenue, Suite AG-6

Carlsbad, CA 92008

Bob Saint 

National Rural Electric Cooperative Association

Mahesh P. Sampat

EMS Consulting

1180 Brookview Dr

Athens, GA 30606

Jerry Schoen

AK Steel Corporation

705 Curtis Street

Middletown, OH 45043

Mike Shannon

RSA Magnet Wire

Chuck Simmons

Progress Energy

Jim Rakowski 

Allegheny ATI
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Antonio Trujillo

Cooper Power Systems

Kenneth Winder

NRECA

Participants from DOE:

Sarah Butler (via webinar)

Dan Cohen (via webinar)

General Counsel

John Cymbalsky

Participants from Navigant/LBL:

Mike Rivest

Navigant

Matt Nardotti

Navigant Consulting

Chris Bolduc

Lawrence Berkley National Laboratory

Berkeley, CA 94720

Katie Coughlin

Lawrence Berkley National Laboratory

Art Rosenfeld (via phone)

LBL

Webinar Attendees

Jerry Allen

Metglas, Inc.

Pam Costello

Navigant Consulting
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Charles Drexler

Ky. Assoc. of Electric Coops.

Brian Kaja

General Electric

Richard Lyke

AK Steel

Dhiru Patel 

Hammond Power Solutions Inc.

Tom Petrosino

TRP Consulting

John Rosetti

Memphis Light Gas and Water

Jeff Schneider

Cooper Power Systems

Thomas Patzner 

Schneider Electric

Bob Smith 

Federal Pacific

Luo Zhimei

Navigant Consulting
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AGENDA

 ITEM PAGE

Welcome, Mr. Parker 211

Self-Introductions 211

Discussion of the Medium Voltage Dry Type 

Transformer Market 218

Final Discussion and Straw Poll 260

Proposal for Next Step 264
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1 9:10 a.m.

3 MR. PARKER: Welcome everyone for day two 

4 of the medium voltage standard discussions. We had 

5 yesterday ... report ... a candid and constructive 

6 exchange of views. It was a tough day. It was 

7 also, by the way, the first day we actually got 

8 proposals from everybody. I do not propose to

9 languish on ... to turn immediately to medium voltage 

10 dry type discussions. I understand there have been 

11 some conversations outside so proposals may be 

12 advanced, so I think the best way to get the 

13 proposals and discuss and -- discuss it briefly, and 

14 then instead of trying to do it as a plenary group, 

15 think about breaking down into subgroups and 

16 caucuses and so forth, to talk about what problems 

17 we have, if any, in this case to resolve.

2 P R O C E E D I N G S

18 Before we get started, let’s go around the 

19 table and introduce ourselves. If you’re on the 

20 phone, please mute your phones so you don’t get --

21 use your phones until you give your name and 

22 affiliation. Let’s start around the table and then 

23 go to the audience, and then the webinar folks. 

24 Self-introductions

25 MR. PARKER: I’m Richard Parker, 
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1 facilitator, University of Connecticut law school.

2 MR. HYLAND: Mike Hyland, American Public 

3 Power.

4 MR. SIMMONS: I’m Chuck Simmons, Progress 

5 Energy and EEI.

6 MR. SAINT: Bob Saint, NRECA. 

7 MR. HIRSCH: Bruce Hirsch, Baltimore Gas 

8 and Electric with EEI contingent.

9 MR. ROSENSTOCK: Steve Rosenstock, Edison 

10 Electric Institute.

11 MR. CASKEY: John Caskey, NEMA.

12 MR. ANDERSON: Rick Anderson, Fayetteville 

13 Public Works Commission, APPA.

14 MR. POLINSKI: Ray Polinski, ATI Allegheny 

15 Ludlum.

16 MR. PETERSEN: Eric Petersen with AK 

17 Steel.

18 MR. PATTERSON: Wes Patterson, ABB.

19 MR. GREESON: Rob Greeson, Federal Pacific

20 Transformer.

21 MR. DeLASKI: Andrew DeLaski, Appliance 

22 Standards Awareness Project.

23 MR. NADEL: Steve Nadel, American Council 

24 for an Energy-Efficient Economy.

25 MR. MILLURE: Dave Millure, Metglas.
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1 MR. HODGE: Gerry Hodge from Howard 

2 Industry.

3 MR. COULTER: Greg Coulter, consultant for 

4 Prolec GE.

5 MR. GAYTAN: I’m Carlos Gaytan, Prolec GE.

6 MR. FERNSTROM: Gary Fernstrom, PG&E 

7 representing PG&E, SCE and Semper Utilities, as well 

8 as west coast perspective. 

9 MR. ECKMAN: Tom Eckman, Northwest Power 

10 and Conservation Council.

11 MR. CORKRAN: Jerry Corkran, Cooper Power

12 Systems.

13 MR. BECK: Scott Beck, Lakeview Metals.

14 MR. BALLO: Tim Ballo, Earth Justice.

15 MR. ROY: Robin Roy, Natural Resources 

16 Defense Council.

17 MR. RIVEST: Mike Rivest, Navigant 

18 Consulting.

19 MR. CYMBALSKY: John Cymbalsky, DOE.

20 MR. BOLDUC: Chris Bolduc, Lawrence 

21 Berkley National Labs.

22 MS. COUGHLIN: Katie Coughlin, Lawrence 

23 Berkley National Labs.

24 MS. DiMASCIO: Marianne DiMascio, 

25 Appliance Standards Awareness Project.
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1 MR. NARDOTTI: Matt Nardotti, Navigant.

2 MR. SAMPAT: Mahesh Sampat, EMS 

3 Consulting.

4 MR. BROWN: Chris Brown, Cogent Power.

5 MR. ANDERT: Gene Andert, Rea Magnet Wire 

6 Company.

7 MR. SHANNON: Mike Shannon, Rea Magnet 

8 Wire Company.

9 MR. SCHOEN: Jerry Schoen, AK Steel. 

10 MR. RYAN: Paul Ryan, Hitachi Metglass.

11 MR. TRUJILLO: I’m Antonio Trujillo from

12 Cooper Power Systems.

13 MR. WINDER: Ken Winder, NRECA.

14 MR. MEYERS: Aaron Meyers, Cooper Power 

15 Systems.

16 MR. RUSH: Ned Rush, consultant.

17 MR. CARMICHAEL: Rob Carmichael, Navigant.

18 MR. COFFEY: Brian Coffey, Navigant 

19 Consulting.

20 (inaudible)

21 MR. TENDULKAR: Vijay Tendulkar, Onyx 

22 Power.

23 MR. BERMAN: Robert Berman, Berman 

24 Economics.

25 (inaudible) 
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1 MR. CREEVY: Jim Creevy, NEMA.

2 MR. RAKOWSKI: Jim Rakowski, ATI Allegheny 

3 Ludlum.

4 MR. FOSTER: Chuck Foster, counsel for 

5 EEI.

6 MR. HOPKINSON: Phil Hopkinson, last, 

7 HVolt, Inc. 

8 MR. PARKER: Okay. On the phone?

9 MR. ALLEN: Jerry Allen, Metglas.

10 (introductions on phone not clear)

11 MR. FINE: Greg Fine (ph), AK Steel.

12 MR. PETROSINO: Tom Petrosino, Prolec GE.

13 MR. PATZNER: Tom Patzner, Schneider 

14 Electric.

15 MR. DREXLER: Charlie Drexler, Kentucky. 

16 Association of Electric Coops.

17 MR. PARKER: Anyone else on the phone?

18 MR. ROSETTI: John Rosetti, Memphis Light 

19 Gas and Water.

20 MR. SMITH: Bob Smith, Federal Pacific.

21 MR. PARKER: Anybody else on the phone? 

22 Okay. Thank you. And thanks again to Mike Hyland 

23 and the American Public Power Association for 

24 hosting us today. I hope you all got some sleep 

25 last night. 
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1 So we’re going to tackle medium voltage 

2 dry types. I know that for various reasons we have 

3 in this committee a number of participants who don’t 

4 have a direct stake in this, the utilities, and may 

5 or may not want to sit in on all of this. I spoke 

6 with ... get this idea to work and he assured me that 

7 it would. Basically, for those people -- everybody 

8 here ... process and for those people who do not wish 

9 to sit in on this because they or their organization 

10 don’t have a problem to raise, they are perfectly 

11 willing, and in fact encouraged to sit -- abstain at 

12 the end and take a break. It you don’t want to sit 

13 in on the discussions you can go wherever you like 

14 and at the end, at the vote, just cast an abstention 

15 or no vote, if that’s your choice.

16 On the other hand, if you wish to 

17 participate, you’re obviously on the committee, and 

18 you’re more than welcome to participate. But I 

19 don’t want people around the table because they’re 

20 on this committee and there’s nothing in our rules 

21 that require that they -- that’s your choice.

22 So, with that in mind, please let’s turn 

23 to the discussion of the medium voltage dry type 

24 transformer market. And we’ll start with proposals 

25 and then have a brief discussion about the 
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1 proposals. Steve, you have a question.

2 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

3 Just real quick, just trying to look at the 

4 presentations that were done by Navigant that were 

5 distributed. The ones I have are dated November 6, 

November 8th, and November 28th 6 . I’m sorry Steve 

7 Rosenstock, EEI. In terms of the dry type the most 

8 recent ones I have would be November 6, 2011, 

9 November 8, 2011, and then one that was e-mailed or 

10 I got on the Sharepoint was November 28, 2011. I 

can read the titles if you want. November 28th

15 MR. BOLDUC: Chris Bolduc, LBL. The most 

recent engineering data is in the November 28

11 was 

12 default scenarios, exclusion scenarios. Again, just 

13 from my review, are those three presentations that 

14 they have?

th

19 MR. ROSENSTOCK: I didn’t print it out.

16

17 version. That you should use as your reference. 

18 And you can look at eleven -- from 11/15 version.

20 MR. BOLDUC: Okay. And that was presented 

21 in the Webinar. So please use that for the 2010 

22 prices.

23 MR. ROSENSTOCK: Thank you very much.

24 MR. PARKER: Any other questions about the 

25 analysis? People have had it, have had a chance to 
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1 look at it. Who would like to present the proposals 

2 first?

3 MR. GREESON: Would it be possible for the 

4 NEMA members to have a brief discussion before we 

5 present this proposal?

6 MR. PARKER: Absolutely.

7 MR. GREESON: Maybe ten minutes.

8 MR. PARKER: Absolutely. Let’s recess for 

9 ten minutes. Ten, 15 minutes? Let’s say 15, give 

10 you time. Coffee and refreshments out there for 

11 those of you who just arrived. We’ll meet back in 

12 15 minutes.

13 (Whereupon, at 9:20 a.m., the meeting was 

14 off the record for a 31-minute period to allow for 

15 caucusing.)

16 MR. PARKER: Take your seats please. We 

17 are now ready for the proposals. 

18 Discussion of the Medium Voltage Dry Type 

19 Transformer Market

20 MR. CASKEY: This is John Caskey from NEMA 

21 and I’m not sure we’re 100 percent ready but we’re 

22 getting close. First of all, I apologize for the 

23 delay, certainly on behalf of NEMA, everything that 

24 we do needs to be like consensus perspective from 

25 our own membership, which is sometimes difficult to 
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1 obtain because we do have a diversity of 

2 manufacturers and other issues within our own 

3 membership. 

4 MR. PARKER: I can’t believe attaining 

5 consensus can be hard.

6 MR. CASKEY: Yes, consensus can be 

7 difficult. But I apologize again for the delay. 

8 Yesterday, I think it was yesterday, that we gave 

9 our proposal relative to liquid filled, and I gave 

10 sort of a spiel on why we really appreciate the 

11 opportunity to thank DOE and the members who are 

12 here, and I basically ditto on all that stuff. 

13 The other thing that I focused on was the 

14 three basic principles that we’ve talked about as 

15 really -- we want to, you know, number one was we 

16 were willing to go higher, we supported going higher 

17 with energy efficiency standards, provided that they 

18 were cost-effective. 

19 The second bullet was related to the 

20 substitution of materials. We wanted to make sure 

21 that whatever we decided as a group basically 

22 there’s a variety of steels to meet that requirement 

23 as well as a variety of manufacturers and steel 

24 suppliers that could meet those requirements, as 

25 well as if there’s some flexibility of design to go 
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1 from copper to steel or aluminum or whatever the 

2 case may be, but some sort of flexibility in the 

3 designs across the manufacturers So that was 

4 another thing.

5 And then the other thing was the impact on 

6 the small manufacturers.

7 So basically where we’re at NEMA with 

8 regard to the medium voltage dry type is one, to be 

9 honest with you, we have more discomfort with the 

10 Navigant and LBL analysis than in some of the other 

11 areas. So fundamentally we have not been able to 

12 get to a good point where we can say, gee, we’re 

13 close enough or we’re in the right ball park. And I 

14 think Wes has done a lot of work trying to explain 

15 that and basically, fundamentally, the slip of the 

16 curve data points between what we, as manufacturers 

17 have, and what Navigant is showing, is different and 

18 I think Wes has been trying to work to get that 

19 resolved. And Mike has been very helpful and I 

20 think, open, in trying to figure out what that 

21 tipping point might be. As of today, I don’t think 

22 we’ve resolved what that difference might be. So we 

23 feel less sort of comfortable with the cost24 effectiveness answers. 

25 So with that, we have gone back and looked 
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1 at the logics ... and things like that as far as that 

2 is factored into our analysis. But all that said, 

3 the bottom line is that what we’re proposing really 

4 comes from where we think there is still reasonable 

5 substitution of steels and a competitive market and 

6 beyond these numbers that I’m giving you, we feel 

7 that the market sort of breaks down and we don’t 

8 have a good open, competitive market. 

9 So the numbers that I have in front of me 

10 here is: 

11 • For DL-9, we’re proposing 1.5

12 • For DL-10, we’re proposing 2.0

13 • For DL-11, we’re proposing 2.0

14 • For DL-12, we’re proposing 3.0

15 I think the DL-11 and 12, at least, 

16 correlate to what the advocates have 

17 recommended so far, as I understand it.

18 • For DL-13, we’re basically - I think we prefer 

19 to be unchanged from the 2010 rule, but in 

20 reality what we’re trying to pave off of is the 

21 DL-12, and we don’t know the number in front of 

22 me here, but what we want to do is allow for 

23 DL-13, which is basically the high BILs, to 

24 have ten percent more losses than the 

25 equivalent of DL-12. We just don’t know 
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1 exactly what that number is, and we’ll work 

2 with the other members at the table to try to 

3 figure out exactly what that is.

4 MR. PARKER: Ten percent more losses than 

5 DL-12, you’re saying?

6 MR. CASKEY: Than DL-12, and the 

7 equivalent of DL-12. So basically, some relief for 

8 the high BILs. We’re saying that’s ten percent 

9 relief, if you will.

10 The other sort of exception or point that 

11 we want to raise deals with the single-phase, and 

12 it’s sort of -- well, we’ve said all along that 

13 there’s this -- it’s not a strict, normalized 

14 relationship between a single-phase and a three15 phase transformer. It’s more difficult to produce 

16 the one than the other. So what we’re saying is for 

17 single-phase that we need less loss reductions than 

18 the equivalent three-phase, and that, again, we need 

19 to come up with some sort of multiplication factor, 

20 however we don’t know what that is yet, but we’re 

21 happy to work with people around the table to get 

22 concurrence on that.

23 So basically I think what we’re saying is 

24 we support pretty much what the advocates had 

25 proposed so far with the exception of some sort of 
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1 special treatment for the high BILs, and some sort 

2 of special treatment for the single-phase.

3 MR. PARKER: Great. Thank you. Let me 

4 note also that, just looking at the shipments data 

5 that I have -- and this is for 2009, but hopefully 

6 it is indicative, that I got from the TSD, DL-9 is a 

7 very small category, as is DL-10. And -- like 23, 

8 257 megavolts (ph) compared to thousands for the 

9 others. DL-13 is also -- I mean DL-13 is also -- 

10 well, it’s significant, but it’s still not very 

11 large. So 11 and 12 is really where the action is 

12 in terms of shipments. Comments? Questions?

13 MR. ROSENSTOCK: Quick question. Steve 

14 Rosenstock, EEI. Was 13 divided into A and B? 

15 Again, I don’t know if that makes a impact on the 

16 votes or not.

17 MR. PARKER: Yes.

18 MR. ROSENSTOCK: I just wanted to know if 

19 that had any effect on --

20 MR. PARKER: Do we have a mic over there?

21 MR. ROSENSTOCK: Oh, okay. I’m sorry. 

22 Steve Rosenstock, Edison Electric Institute. My 

23 only follow-up question was, for DL-13, there was an 

24 A and B category, so I didn’t know if that had any 

25 impact on the proposal, if they were separate
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1 numbers or issues, just as clarification.

2 MR. CASKEY: This is John Caskey, NEMA. 

3 Basically where there were two categories, once you 

4 go to the DL-12 level and sort of back off of that, 

5 essentially, and I don’t know what that number is.

6 MR. DeLASKI: Can you explain that, John? 

7 DL-12 level --

8 MR. PARKER: Sorry, give your name, 

9 Andrew.

10 MR. DeLASKI: Andrew DeLaski. For DL-13, 

11 you want to -- just say it again.

12 MR. CASKEY: To be honest with you, I 

13 cannot explain it very well. What we are looking 

14 for -- I wish I could, but the facts are the facts. 

15 So basically, what we’re looking for is ten percent 

16 more loss than what’s available in the DL-12 

17 category. So we need to go through and look at the 

18 watt loss in the DL-12 category, and then that’s a 

19 DL-3 level, and then basically allow for ten percent 

20 more losses in that calculation. I’ll be happy to 

21 turn the microphone over to Wes to see if he can 

22 make more sense out of it.

23 MR. DeLASKI: Let me just try something, 

24 let me -- so I have a DL-12, at an EL-3, my 

25 calculation shows the reduction in losses is 30.7 
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1 percent. So then what would it be for the DL-13?

2 MR. PATTERSON: It would be roughly point 

3 nine times 30, ninety percent of the 30. Ten 

4 percent less.

5 MR. DeLASKI: Twenty-seven reduction in 

6 losses for DL-13 is the proposal?

7 MR. PATTERSON: Yes. It should be a ten 

8 percent differential.

9 MR. DeLASKI: Which is -- okay.

10 MR. PATTERSON: Somewhere between the two 

11 and three. Wes Patterson. As a clarifying 

12 statement. The existing standard pretty much set 

13 their loss level at the 95 BIL ratings, and the 95 

14 BIL ratings is the large sweet spot of the market. 

15 The 125 BILs, the higher BILs, are essentially three 

16 to four percent higher in losses in the existing 

17 standard. I’m not sure how the three to five 

18 percent was arrived at, but technically, these 

19 numbers should be at least ten percent more losses 

20 because of the increased ... required to drive that 

21 transformer. It’s making the core much larger. 

22 MR. RIVEST: This is Mike Rivest. I can 

23 confirm that a baseline design line like the G 

24 transformer is having to use more advanced steels to 

25 meet the standard that ...
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1 MR. DeLASKI: Right, so I’m looking at EL 

2 to come out to some -- I’m looking at EL, take 13B, 

3 which I think is the main one here, and I’m seeing 

4 EL-3 is 27.1 percent loss reduction. Is that what 

5 you’re seeing?

6 MR. GREESON: This is Rob Greeson, Federal 

7 Pacific. What percent efficiency is that?

8 MR. DeLASKI: This is just our chart, --

9 MR. GREESON: 13A or 13B?

10 MR. DeLASKI: 13A was 98.92, 13B was 99.0, 

11 EL-3.

12 MR. GREESON: EL-2 by my numbers is 23.6 

13 reduction ... (not at mic) ... want to look at it in 

14 terms of the EL --

15 MR. SMITH: Richard, good morning. This 

16 is Bob Smith of Federal Pacific. I would like to 

17 offer a comment on the single-phase transformers 

18 that John mentioned, if I may?

19 MR. PARKER: Can you hold on just one 

20 second so we can finish this conversation that was 

21 going on here.

22 MR. SMITH: Okay. That would be great.

23 MR. PARKER: Thank you. We’ll get right 

24 back to you.

25 MR. DeLASKI: So on 13B, at what EL?
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1 MR. GREESON: At EL-3, I had 27.1 percent.

2 MR. GREESON: Okay. I have 27 percent, 

3 and that 27 percent represents 6200 watts losses. 

4 Okay. So we’re proposal then is 6200 watts times 

5 1.1, which is 6820.

6 MR. DeLASKI: Okay. Got it.

7 MR. PARKER: Okay. Bob, did you want to 

8 comment?

9 MR. SMITH: Yes. Thank you, Richard. On 

10 the single-phase medium voltage dry type 

11 transformers, many of those are used by electric 

12 utilities in high rise downtown condominium and 

13 office buildings. We need to be very careful about 

14 raising the efficiency of the single-phase 

15 transformers for these applications. We call them 

16 high-rise transformers because they need to go up 

17 and down elevators, and in some cases they have to 

18 be taken apart because of their weight and size. 

19 These transformers have one very common attribute, 

20 and that is they have to be operated at a very low 

21 sound level. And regardless of which core steel we 

22 use, whether it’s M4, or M3 or whatever, the way we 

23 get low sound is to lower the induction level of the 

24 transformer core. And as we do that, it makes the 

25 product larger. So I just encourage us to be very 
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1 careful about what efficiency we pick for the 

2 single-phase because it will have the same impact on 

3 the electric utilities as the increased size for the 

4 network transformers.

5 MR. PARKER: Thank you, Bob. Wes.

6 MR. PATTERSON: On the single-phase units, 

7 I don’t believe we discussed the actual level. In 

8 the existing standard, the efficiency of a three9 phase KVA, let’s use an arbitrary number --

10 MR. PARKER: Get closer to the mic, Wes.

11 MR. PATTERSON: In a three-phase 

12 transformer, let’s use an arbitrary number. Let’s 

13 say for 100 KVA three-phase, there’s a standard that 

14 is the existing standard says that 100 KVA single15 phase will have the same efficiency. We’re indexed 

16 to be exactly the same. This is incorrect. 

17 Technically, with a dry-type transformer, 

18 the losses in the single-phase transformer will be 

19 33 percent more because I have this extra amount of 

20 core steel in its construction. And this extra loss 

21 should be accounted for in the standard. So our 

22 proposal would be that for single-phase, whatever 

23 the standard is set for three-phase, the losses be 

24 increased 30 percent for the single-phase equivalent 

25 KVA. So on a 100 KVA three-phase transformer, if it 
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1 had 100 watts loss, then for 100 KVA single-phase 

2 transformer, I would have 130 watts loss. That 

3 would be our proposal.

4 MR. DeLASKI: I’m looking to the 

5 consultants. We went through this last time around, 

6 I used DLEs (ph) one to the other, is that similar 

7 to the first scaling the Department used in the 

8 past?

9 MR. PATTERSON: No.

10 MR. DeLASKI: It’s not?

11 MR. PATTERSON: No. This is Wes. What 

12 was used in the past was an assumption that the 

13 efficiencies had to be equal to prevent 

14 circumvention from a single-phase circuit to a 

15 three-phase circuit. Given the size of these units, 

16 recognizing Bob’s comment, most of them are used in 

17 buildings like this. There’s not enough room to put 

18 three single-phase units as an option. It’s 

19 physically impossible. So they won’t be 

20 circumvented by trying to substitute three single21 phase for a single three-phase.

22 MR. SAMPAT: Mahesh Sampat. Remember the 

23 standards, it’s not ... single-phase ... at the same 

24 efficiency. It’s connecting a single-phase at 300 

25 KVA would have the same efficiency. Correct me if 
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1 I’m wrong.

2 MR. PATTERSON: No, I agree with that 

3 also. Our proposal is there’s 30 percent 

4 differential for the same KVAs.

5 MR. SAMPAT: Okay. So I think that’s what 

6 --

7 MR. PATTERSON: Whatever the end resulting 

8 numbers are, we need this 30 percent differential.

9 MR. SAMPAT: Right. On the same KVA 

10 basis.

11 MR. PATTERSON: On the same KVA basis.

12 MR. DeLASKI: So let me just comment that 

13 the way I see the numbers and sales, the single14 phase is one percent.

15 MR. PATTERSON: Yeah, that’s about right. 

16 It’s small.

17 MR. DeLASKI: One percent of the total 

18 sales of the medium voltage transformers are single19 phase.

20 MR. PATTERSON: It’s less than small. 

21 It’s at least less than five.

22 MR. DeLASKI: So taking that into account, 

23 you know, this is not what we need to spend a lot of 

24 time on.

25 MR. GREESON: Rob Greeson, Federal 
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1 Pacific. Given Bob’s comments, though, of high rise 

2 and weight, Bob, I guess you’re listening to this, I 

3 know --

4 MR. SMITH: I try to listen. I hope you 

5 guys could get closer to the microphone.

6 PARTICIPANT: (on phone) I wish you guys 

7 could get closer to the microphone also.

8 MR. GREESON: What I was going to propose 

9 is, being a smaller segment of the market, rather 

10 than -- and we’re concerned about the weight, could 

11 we just agree to leave the single-phase unchanged at 

12 this point and not have to go through the process of 

13 arguing what multiplier to use and given the 

14 uncertainties about the weights of the transformer, 

15 and its market share, I think it might expediate the 

16 process a little bit.

17 MR. DeLASKI: This is Andrew to follow up. 

18 The proposal from NEMA, as I understand it, was 

19 losses be increased by 30 percent for equivalent

20 KVA. 

21 MR. PATTERSON: For the three-phase.

22 MR. DeLASKI: Low losses equals lower 

23 efficiency. And have you guys calculated what kind 

24 of change that is, to the EL level?

25 MR. PATTERSON: No, I haven’t.
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1 MR. DeLASKI: So how close is that to no 

2 change, Rob, I guess is my question.

3 MR. GREESON: I don’t know.

4 MR. DeLASKI: You don’t know. All right. 

5 So -- and we’re not going to go backwards, 

6 obviously. We’re not allowed to go backwards. The 

7 standard increase has to be positive.

8 (Discussion off mic)

9 MR. PATTERSON: So we could change our 

10 proposal to be -- change our proposal to be either 

11 no change or supports the 30 percent differential.

12 MR. DeLASKI: To my way of thinking, I 

13 think some increase does make sense, so that we are 

14 minimizing the risk of the loophole that was a 

15 concern the last time around, that would be my 

16 inclination.

17 MR. PARKER: Do we have any other 

18 clarifying questions?

19 MR. POLINSKI: Ray Polinski, ATI 

20 Allegheny. Yeah, I just wanted to respond to John 

21 and NEMA’s proposal, and I want to make a few 

22 comments -- I’m speaking here from ATI Allegheny 

23 Ludlum perspective. I can’t say I’m speaking for AK 

24 as well -- Eric will speak for AK. 

25 But first off, as far as this whole medium 
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1 voltage dry, we spent so much time on the liquid 

2 tweaking the model and working with things, you 

3 know, became -- personally became very comfortable 

4 with the analysis. It wasn’t perfect, but, you 

5 know, in blending industry and the model and working 

6 through it, kind of said, hey, the conclusions were 

7 very close. We really have not spent a lot of time 

8 on this.

9 But, you know, my position, dating back to 

our group’s conference call on November 17th 10 , we had 

11 a conference call on the medium voltage dry, my 

12 position has been that the workhorse for this 

13 product today, the workhorse for wound core and for 

14 liquid filled is M3. The workhorse grade for this 

15 market is M4. And so in my view, M4 was a grade 

16 that needed to remain competitive to insure there 

17 was adequate supply and no shortage of supply. 

18 Again, that’s been my position from that conference 

call on November 17th

20 Now the problem that I’m having is that if 

21 you look at the Navigant data, where M4 remains 

22 competitive is kind of a EL-1, kind of across the 

23 board. Mostly we’re talking about the design lines 

24 11 and 12 where the majority of the volume exists. 

25 Now, when I break out -- we haven’t had a chance to 

19 .
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1 have a debate or discussion about this level, but 

2 Wes’ data, again, you know, Wes assures me that 

3 these levels here that NEMA is proposing, M4 is 

4 competitive. But it’s a big difference from his 

5 data to the Navigant data. 

6 And I talked with Rob Greeson a little 

7 bit, who’s another significant player in this 

8 market, and Rob, the last time I talked with Rob he 

9 wasn’t sure -- well, I don’t know maybe it’s more M3 

10 -- M3 I just don’t think would go through. But 

11 these transformers which have a lot of labor 

12 involved with stacking laminations, as I say, M4, 

13 .27 millimeter thick materials have been the 

14 workhorse.

15 So I’m just trying to frame -- I would 

16 love -- if Wes’ data is correct, then I would love 

17 to get in line with the NEMA recommendations. But 

18 right now, based on the 2010 Navigant engineering 

19 analysis data, I’m kind of stuck more to the EL-1, 

20 consistent with M4 continuing to be a competitive 

21 grade, which is -- for this medium voltage dry. So 

22 just wanted to go on record with that.

23 MR. PARKER: Thank you. Eric.

24 MR. PETERSEN: I want to ask a clarifying 

25 question. On the NEMA proposal -- Eric Petersen, AK 
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1 Steel. You mentioned that you were setting the 

2 efficiency levels you established based upon 

3 availability of supply. What grades of steel are 

4 you considering are available in supply? Let’s just 

5 say in design lines 11 and 12. Are you trying to 

6 provide availability of H-0s and H-1s? Of M3s? 

7 M2s? M4s? What is the supply basis that you 

8 believe to be available.

9 MR. CASKEY: Wes can answer.

10 MR. PATTERSON: Wes Patterson, ABB. Eric, 

11 what we would see is predominantly M4 and H-0 and H12 1, and some M3. As Ray noted, challenge with M3 is 

13 the thickness of the steel, right? And the thinner 

14 you make the steel, the more labor you put into it. 

15 But from capabilities, we could use M3, we could use 

16 M2. We’ll definitely end up with M4. You will 

17 definitely end up with the laser scribe products.

18 MR. PETERSEN: If I can just respond, 

19 then. AK Steel is in a unique position here within 

20 -- as we start talking about the M4s versus the H-0s 

21 and H-1s, that representing the steel industry, we 

22 certainly agree with efficiency levels that allow 

23 for M4. And I think some of the challenges is we’re 

24 really outrunning the headlights, so to speak, of 

25 the DOE data, struggling to understand whether or 
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1 not what the DOE’s got is really representative of 

2 what the transformer manufacturers really provide. 

3 So we’re going to have to lean largely upon what the 

4 transformer manufacturers are stating is available. 

5 But we are fully in support of a efficiency level 

6 that would result in M4 being available as that is 

7 something that there would be a -- plenty of supply 

8 for the transformer manufacturers, it’s in their 

9 best interest. My concern would certainly be, 

10 though, that if the efficiency levels that are 

11 provided result in the use of H-0 type products, AK 

12 Steel is the only domestic supplier within the 

13 states associated with a high V (ph) products, so 

14 our concern would be that if you’re pushing 

15 efficiency levels that place us as the only 

16 supplier, you’re essentially giving us -- I don’t 

17 want to call it a monopoly position, but you’re 

18 essentially giving us the point of supply, and I 

19 would challenge transformer manufacturers that 

20 that’s the best interest of the industry.

21 MR. PARKER: So you object to this?

22 MR. PETERSEN: What I’m saying is 

23 unfortunately I can’t tell -- you know, I’m 

24 dependent upon the transformer manufacturers here 

25 associated with what they can do. If they’re 
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1 confident that this gives them an M4 in both DL 

2 scenarios, I’m comfortable with it. If, however, it 

3 puts them just at H-0 and H-1, my concern is, I’m 

4 your only supplier, and I just question whether 

5 that’s the best interest for the industry.

6 MR. PATTERSON: Wes Patterson. Eric, the 

7 -- I presented or distributed a presentation showing 

8 the core steel grade distributions that are 

9 currently used at different energy efficiency levels 

10 and this standard was set at those levels.

11 MR. PARKER: Wes, could you speak right 

12 into the mic? Please.

13 MR. PATTERSON: And the presentation I 

14 gave at this EL-3 level, shows that the dominant 

15 steel today is M4, and we do use some laser-scribed 

16 in that production space. But from an engineering, 

17 technical perspective, I can flip-flop back and 

18 forth between the laser-scribe and the M4, and it is 

19 solely driven by the relevant price of the two 

20 materials. So M4 will stay as an option to be used, 

21 as long as its price is competitive with laser22 scribe. If that price differential shifts, then for 

23 sure we will move all our production over to laser.

24 MR. PETERSEN: Can you comment on design 

25 line 11?
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1 MR. PATTERSON: Same.

2 MR. PETERSEN: Same look?

3 MR. PATTERSON: Yes.

4 MR. PETERSEN: Okay. 

5 MR. PATTERSON: The only difference 

6 between 11 and 12 is the KVA rating.

7 MR. PETERSEN: Okay. So, again, Eric 

8 Petersen, AK Steel. Since this is a unified 

9 transformer manufacturer’s position, and if all of 

10 them are in agreement here, that M4 is a product 

11 that will be dominant, that satisfies my concern 

12 that they’re not moving to a situation that I’m the 

13 only supplier of it, and in my opinion it would make 

14 good sense and I would support it.

15 MR. SMITH: Bob Smith, Federal Pacific. 

16 What thing to remember about the dry type 

17 transformers is that for the most part, we are not 

18 going into a market that is evaluating core losses 

19 and load losses. So the need for very low loss core 

20 steel is going to be much less for the medium 

21 voltage dries than it will be for the medium voltage 

22 liquids. And I think that’s one of the reasons that 

23 you’ll find that the M4 will be more predominantly 

24 used.

25 MR. PARKER: Rob?
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1 MR. GREESON: Rob Greeson, Federal 

2 Pacific. I issued, and it’s on the record, I issued 

3 on Sharepoint, what my estimates were, the breakdown 

4 would be. They didn’t totally match up with what 

5 Wes came out, I just want to be clear as far as my 

6 information is, we don’t have the level of 

7 experience that ABB does at the higher grades of 

8 steel. I give a lot of weight to what he’s saying. 

9 When you look at my numbers, you have to understand 

10 we haven’t had as much experience because, you know, 

11 you can just ask me, without talking to Wes, and 

12 with the level of experience we’ve got, I would have 

13 said we would probably use some M4, and maybe shift 

14 it a little more towards the M3. Wes is very 

15 adamant, tells me hey, you can do it with M4 and had 

16 some discussions, did this little presentation, and 

17 it was really -- this wasn’t an easy thing for me to 

18 come up with, I had to kind of make a lot of 

19 estimations, so I guess what the bottom line is, I 

20 believe that you can probably do it with M4, I just 

21 haven’t -- the paper that I submitted may not say 

22 that, but I believe that given what Wes has said, 

23 some discussions I’ve had since, that there will be 

24 competing core steels.

25 But my initial analysis kind of looked 
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1 like it was leaning towards the M3. M3 is a more 

2 efficient steel and you can leverage it a little bit 

3 better, but it’s awfully -- with the market swings 

4 and how things work in the market with price, so 

5 there’s a lot of variables.

6 MR. PATTERSON: This is Wes again. One 

7 more comment on this. I do have the -- Mike’s 

8 position that I buy steel from both of our CGO 

9 suppliers, and they both know exactly what my 

10 purchase records are. And they also know exactly 

11 what factories they go into. So internally they can 

12 check the records. The only thing they don’t know 

13 is the volume of my production that meets the 

14 efficiency level, and the volume of my yearly 

15 production that meets an EL-3 is roughly 20 percent.

16 MR. GREESON: Rob Greeson, Federal 

17 Pacific. Even if I decided to buy only M3, he still 

18 buys a lot of M4. He buys a lot more than I could.

19 MR. POLINSKI: Ray Polinski, ATI 

20 Allegheny. And again, just as I’ve been consistent 

21 on the liquid filled as well as from this 

22 standpoint, I just feel it’s consistent with the DOE 

23 practices and the process that the data that I --

24 that is validated, that I think the DOE has to make 

25 their decision based on, it’s the Navigant and DOE 
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1 data, and so I just present the crossover points on 

2 the data -- that has been at EL-1 for M4. Now if 

3 there -- some work needs to be done, and I don’t 

4 want to -- I’d love to have data that support --

5 that’s more consistent with Wes’ data that I could 

6 then, you know, say to my management team, hey, this 

7 is the data, M4 is in the game, and yes, I can agree 

8 to this level. But, you know, without that -- so I 

9 don‘t know -- I don’t want to delay the process, but 

10 if we can get some more clarity from -- on the data, 

11 then some of the plots change according, other than 

12 that, I have to be -- because I am consistent with 

13 the liquid filled, I have to vote based on the 

14 Navigant, LBL data.

15 MR. PARKER: Okay. Thank you, Ray. 

16 Andrew.

17 MR. DeLASKI: Ray, I appreciate that 

18 comment and I appreciate your striving for 

19 consistency. I -- let me just say that what we 

20 agree to in this conversation does not commit you to 

21 anything else, in my view. I’m not going to say, 

22 Ray, over there you said okay because -- and what 

23 you said here somehow ties your hands in liquid 

24 immersed. I wouldn’t hold you to that, what you’re 

25 holding yourself to. Each discussion is an 
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1 independent discussion. I know it affects your 

2 business. Each of them affects your business, but I 

3 think we should have come to ... here, independent, 

4 not for a -- create some decisionables -- some 

5 decisionable by year, somehow has to be applied in 

6 either low voltage, low voltage dry or liquid 

7 immersed. I just want to be careful that we don’t -

8 - if we do that kind of thinking, I’m afraid we’re 

9 going to tie ourselves up in knots and really 

10 prevent ourselves from getting to yes.

11 MR. POLINSKI: Ray Polinski, ATI 

12 Allegheny. Thanks, Andrew, for the comments. And 

13 my only -- my point is that I thought, you know, 

14 from my viewpoint, my opinion, is that all the back 

15 and forth, and all the files and e-mails and then 

16 trees we’ve killed with all the paper on this 

17 project, is that the -- it’s been good. The 

18 Navigant model and the industry model has gotten 

19 close enough together that everyone said, you know, 

20 for all practical purposes, the conclusions were 

21 very similar. And we just haven’t -- I don’t 

22 believe we’ve done anything to tweak the dry type 

23 model, and so that’s my problem, is that we’re just, 

24 you know, just a little bit like ... where you have 

25 these two data sets that are wildly different 
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1 conclusions or whatever, and I’m just having a hard 

2 time deciding which one to take as gospel. So 

3 that’s where I’m kind of stuck.

4 MR. PARKER: Andrew.

5 MR. DeLASKI: And I guess I think, Ray, 

6 the difference -- a bit of difference, I think, in 

7 this situation is that here you have the 

8 manufacturers making a proposal as a whole, and that 

9 puts us in a little different spot than we are with 

10 the other discussion. I think the market data, in 

11 this case I think we have market data that is 

12 inconsistent with the Navigant data, and that we can 

13 use -- I suspect that with additional conversations 

14 that Mike’s data will change. I think running out 

15 of time is our problem, so -- for negotiated 

16 outcomes. So there could be contested outcomes and, 

17 you know, that’s another -- then they’ll go where 

18 they’re going to go in contested outcomes. But I 

19 think it’s sort of a paralysis by analysis risk that 

20 we face, and that the market data speaks loudly. 

21 We should consider both as opposed to 

22 saying the Bible or the iron-clad rule of Mike’s 

23 plots. Because I think if we retire some of Mike’s 

24 plots ... we’ve got to be careful about that.

25 MR. PARKER: So, Andrew, did you want to 
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1 respond now to the NEMA proposal or should we take a 

2 break --

3 MR. CASKEY: Can we let Vijay, as another 

4 manufacturer --

5 MR. PARKER: Yes, absolutely. Vijay, I 

6 didn’t see your hand, I’m sorry. Go ahead, please.

7 MR. TENDULKAR: This is Vijay Tendulkar 

8 from Onyx Power. We make two medium voltage 

9 transformers, we’re not a big manufacturer. And the 

10 problem is all these materials we’re trying to use, 

11 M4 and laser material, if you wanted to use the 

12 whole variety of those materials, you have to have 

13 fully mitered construction. And as a small 

14 manufacturer we’d have to put out a lot of money to 

15 get that ... and to get the efficiency requirements. 

16 The second part is that there are 

17 manufacturers around here that are really qualified 

18 and sophisticated in their attempts to make use of 

19 the various materials and other things. We tried to 

20 use it and we had problems. And none of these 

21 transformers, we have found out, that they have 

22 tested very well when at room temperature, but at 

23 the high temperature the core losses went up. That 

24 is not expressed in any data in any of this 

25 discussions here. The core losses went up 25 
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1 percent. That is really a ... of the transformer. At 

2 room temperature, the core losses are correct, what 

3 we calculated. I don’t know if anybody tested this, 

4 and I don’t know how we small manufacturers can get 

5 all this technology immediately to meet the new 

6 efficiency requirements.

7 PARTICIPANT: (on phone) Can you get a 

8 little closer to the mic, I can’t hear a thing.

9 MR. PARKER: Okay. Let’s ask everybody to 

10 wait until you have the mic in your hands and hold 

11 it up to your mouth so ... and speak your piece. 

12 Okay, John.

13 MR. CASKEY: John Caskey, NEMA. Can we 

14 get a clarification on technology relative to this 

15 work. As I understand this, the mic is amplified in 

16 the room, but it’s not translated to the 

17 speakerphone, is that correct, and that these little 

18 things on the table are what’s connected to the 

19 speakerphone?

20 MR. HYLAND: Let me explain. This is Mike 

21 at APPA. The little microphones that are on the 

22 table are for her, and her alone, for the record. 

23 This microphone, this star contraption, there with 

24 those two coming off of it, are the phone that 

25 they’re listening to on line. The microphone is 
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1 only for internal and is not tied to anything.

2 MR. CASKEY: Okay. So when we have sort 

3 of speakers, if you will, we need them to get close 

4 to one of these devices in order for them to pick it 

5 up.

6 MR. HYLAND: Yes.

7 MR. CASKEY: Okay. So I don’t --

8 MR. HYLAND: Every time they use the 

9 microphone, it should be loud enough to pick it up, 

10 if they speak loud, like I do.

11 MR. CASKEY: I’m loudly without the 

12 microphone.

13 MR. DeLASKI: So this is Andrew. We --

14 there’s a significant amount of work put into this. 

15 We made our proposal at our phone call, I guess two 

16 weeks ago, before Thanksgiving, and for design line 

17 11 and design line 12. The NEMA proposal matches 

18 our proposal for those two design lines, so we think 

19 that -- we really appreciate that NEMA matches our 

20 proposal. Those two design lines represent, as we 

21 understand from the DOE data, something on the order 

22 of 60 percent of sales -- that’s from the DOE data. 

23 So it is a majority of data with regard to sales. 

24 So we have agreement with NEMA on those categories.

25 The other categories, we don’t have a DOE 
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1 analysis that has been completed -- or a completed 

2 LCC analysis, but what I understand from the 

3 description that was presented to us by NEMA and the 

4 manufacturers is that they’ve done the analysis, 

5 they’ve done the translation to these other 

6 technologies. For example, for design line 13, 

7 which is the next largest category, by far, design 

8 line 13 being approximately, oh, call it 30 percent 

9 of the market, they’re proposing a break, the ten 

10 percent more losses than design line 12. So 

11 something of a break, of a lower standard that 

12 proposed for the same transformers -- same size 

13 transformers covered by design line 12. And I might 

14 corroborate that engineering difference. So based 

15 on that, we’re comfortable with the NEMA proposal as 

16 it has been made.

17 MR. PARKER: Thank you, Andrew. If I can 

18 just clarify one thing. Design lines 11 and 12 

19 currently are both grouped under equipment class 

20 eight, and the proposal is two different ELs for 

21 those. I take it that one way to get there on your 

22 proposal would be just to propose creating a 

23 separate equipment class for 11 and 12?

24 MR. DeLASKI: No, I don’t think we need a 

25 new equipment class because there’s a whole range of 
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1 KVAs, so you have to scale -- you have to scale from 

2 the design line across the range of KVAs. Keep the 

3 equipment classes the same. I think what we would 

4 do with this, we’d have to do the absolute values, a 

5 table of KVAs for something that we look to, the 

6 consultants could develop in its recommendation. 

7 DOE and their consultants have a table based on 

8 these decisions, these recommendations. We all have 

9 to view it and make sure it makes sense.

10 MR. PATEL: This is Dhiru Patel from 

11 Hammond. May I comment?

12 MR. PARKER: Excuse me, Andrew, were you 

13 finished?

14 MR. DeLASKI: Yeah.

15 MR. PATEL: Hello?

16 MR. PARKER: Yes, go ahead please.

17 MR. PATEL: This is Dhiru Patel from 

18 Hammond Power Solutions. Regarding the scaling, we 

19 at Hammond, we did ... designs for the design line 

20 that is given by -- as a proposal. And then we 

21 started looking at these smaller ratings because 

22 smaller things are typically the bore issues, so on 

23 the design line ... KVA and 95 KVA and we checked that 

24 and then ... to 225, 75, and smaller to 15 for 95 

25 KVA. And we do the scaling that ... efficiency and we 
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1 tried to ... KVA and smaller, we are finding very, 

2 very difficult to improve on the level that the 

3 current DOE regulations. And the reason being, ... 

4 smaller, the core becomes smaller but the clearance 

5 to the core and the ... fan, because it is ... by the 

6 BIL level and the voltage drop of the winding. 

7 So what happens is on the smaller units, 

8 the core is much larger proportioned than the coils, 

9 and you have to achieve that efficiency by 

10 incrementing the core. Now you have a small core, 

11 the ... also is smaller and there’s a higher effect on 

12 the ... KVA. And that also will help in the 

13 improvement in the efficiency. So until the scaling 

14 factor is known, that what kind of efficiency will 

15 be proposed for smaller KVA, it is very difficult to 

16 even comment. Because I know from 15 to 35 KVA, the 

17 slightest improvement on the current level is almost 

18 impossible with the steel going from M6 to M3 ...

19 We considered the ... etched, but with a 

20 very small space, it’s very, very difficult. Any 

21 comments from anybody else?

22 MR. PARKER: Okay. Vijay, if you can come 

23 and stand next to the star mic so people on the 

24 phone maybe can hear you? Speak into that mic.

25 MR. TENDULKAR: This is Vijay Tendulkar, 
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1 Onyx Power. I looked at our numbers, we are going 

2 to reduce our losses by 35 percent, and we have done 

3 some calculations in our company, and I don’t think 

4 we can make any of those losses by 35 percent lower 

5 than that. Maybe we can go somewhere around 15 

6 percent or something improvement, but not 30 

7 percent. Thirty percent will be impossible for us 

8 with our current technology and the equipments we 

9 have, we’d be very hard pressed to do that. I don’t 

10 think we will meet it. We’ll have to get out of 

11 this distribution transformer market completely.

12 MR. RIVEST: Mike Rivest, Navigant. Just 

13 to clarify. Are you --

14 MR. PATEL: I can’t hear -- much louder.

15 MR. RIVEST: This is Mike Rivest. 

16 Clarifying question. Are you in all segments of 

17 this market, or are you only in some of the 

18 representative units.

19 MR. TENDULKAR: Medium voltage dry types.

20 MR. RIVEST: Are you in all BIL and all 

21 KVA ranges as well?

22 MR. TENDULKAR: Up to 95 KVA BIL, about 25 

23 KVA.

24 MR. RIVEST: So -- okay.

25 MR. PARKER: And this is not your data 
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1 set, these are all --

2 MR. TENDULKAR: These are separate 

3 distribution transformers.

4 MR. PARKER: Steve, did you --

5 MR. ROSENSTOCK: Are you taking more 

6 comments or --

7 MR. PARKER: Yes.

8 MR. ROSENSTOCK: Who was first?

9 MR. GREESON: Rob Greeson, Federal Pacific 

10 Transformer.

11 MR. PARKER: Rob, can you come over here 

12 again to the mic.

13 MR. GREESON: From Hammond’s discussion of 

14 scaling factor, I’ve run into the same issue. I 

15 haven’t looked at it in quite the detail it sounds 

16 like he did, but from the work that I did, when you 

17 get into those smaller KVAs, you do have those 

18 problems. It’s harder to meet those efficiencies. 

19 There may very well be a problem on the lower end 

20 KVAs. The work that I did, I concentrated on the 

21 300 and the 1500, but you know, you’ve got a lot of 

22 KVA sizes that are covered below 300 KVA. I don’t 

23 think it’s unreasonable to expect that maybe the

24 scaling factor is somewhat higher than what your 

25 efficiencies -- they might be tapered down a little 
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1 bit on those lower KVAs. But from the advocates’ 

2 standpoint, I don’t think the MVA shipments from 

3 those lower KVAs are an issue. In the last meeting, 

4 I think we even talked about making -- leaving some 

5 of those KVAs alone.

6 MR. PARKER: Do we have any data on what 

7 the shipments are for the 15 to 30 KVAs?

8 MR. GREESON: There might be -- I think 

9 that might be an issue. He’s right about the 

10 construction factor and the proportionality of the 

11 core, of the losses to the overall losses. It 

12 increases and because -- it’s the nature of the 

13 design.

14 MR. DeLASKI: This is Andrew. I, again, 

15 our focus is on energy savings. And my 

16 recollection, as Rob points out, that we have had 

17 this conversation in earlier meetings. The extent 

18 of that conversation, we’ve been around this, and we 

19 agree that -- I think, Mike, from talking to you and 

20 talking to Wes, how do you scale down, and that 

21 there are these edge effects, or call them ... effects 

22 of some sort, that you can’t use this scale. So I 

23 guess we look to you, to work with you guys, to 

24 figure out how to do that scaling, and come back 

25 with the table and then react to that. In 
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1 principle, we’re agreeing that you have to -- there 

2 would be some need to address the smallest -- the 

3 smallest products -- not with the same factor, 

4 right.

5 MR. GREESON: I think we agree, then.

6 MR. DeLASKI: Yes, I think we agree.

7 MR. PARKER: Steve Rosenstock.

8 MR. ROSENSTOCK: Steve Rosenstock. I 

9 appreciate the presentations and I’m looking at the 

10 analysis that’s stated in November 28, 2011, the 

11 most recent analysis for the medium voltage dry type 

12 transformers. I’m looking at slide five, design 

13 line 11, LCC default results, which is all the 

14 materials, all metals. At level two, what I’m 

15 seeing here is a 58.75 percent of ... net increase in 

16 life cycle cost, 41 percent -- 41.25 percent on the 

17 savings of LCC, and mean and median LCC savings for 

18 EL-2 at design line 11, default results, .... That’s 

19 slide five. That’s the slide. That’s correct. 

20 So, looking at the economic justification, 

21 I do have some concerns with that one. 

22 Looking at design line 12 on the next 

23 slide, the -- in terms of LCC savings for design 

24 lines one and two both have 90 percent of 

25 transformers have net LCC savings. Design line two 
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1 has higher mean LCC savings than design line three 

2 median savings. 

3 Then when I scroll down to the payback 

4 numbers on slide seven, design line 11, I’m looking 

5 at the payback periods and for design line two, a 

6 mean payback period of 26.9 years, median of 20.2 

7 years. Much higher than what’s with EL-1. And then 

8 on design line 12, 15 years for design line three, 

9 nine years for two, six years for one. And then of 

10 course you have the median and the average ones as 

11 well.

12 So I appreciate -- and then there’s a 

13 metals and transformer -- so I like the fact that 

14 the parties are coming together, but I’m worried 

15 about some of the economic impacts of some of the 

16 these levels. So I don’t know if we’re going to do 

17 a series of straw votes. I would not mind seeing --

18 at least allowing us to vote on levels one, and two 

19 for design line 11, and one, two, and three for 

20 design line 12. I’m not making any comments on 

21 nine, ten, and 13.

22 We do have some economic analysis for 

23 nine, ten, and 13 -- I remember. I do have that 

24 presentation -- don’t use that any more? Okay. I’m 

25 sorry. But there must have been some printed 
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analysis, so I’m just using November 28th

5 MR. PARKER: Okay. A couple more brief 

6 comments, then I do think we should break for a few 

7 minutes to let people talk.

1 , so I just 

2 wanted to, just from the analysis that was

3 published, just wanted to point some of those out 

4 for people. Thank you very much.

8 MR. POLINSKI: Ray Polinski, ATI 

9 Allegheny. Andrew, you had mentioned previously, 

10 though, in a comment that consistency amongst what 

11 we do for this one -- this dry type medium voltage 

12 maybe doesn’t apply to the dry -- I mean the medium 

13 voltage liquid filled. And so, anyhow, just from a 

14 consistency standpoint, I hear what you’re saying. 

15 You’re saying, hey, the manufacturers, the 

16 transformer producers, you know, they’re making a 

17 recommendation and they don’t want to put themselves 

18 into a non-competitive situation when it comes to M4 

19 and core steel and things of that nature. And I hear 

20 some other comments.

21 So I’m kind of -- I kind of initially had 

22 said that an EL-1 across the board. And so 

23 consistent with that movement in that direction, I 

24 think I could probably move to an EL one and a half, 

25 still not to where the group is, and -- but a little 
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1 bit on the same vein though, I would ask that you, 

2 and your group, would listen to the manufacturers on 

3 the liquid filled medium voltage as well. I mean, 

4 they’ve spoken, and you -- you’re asking me to put a 

5 lot of weight on what they’re saying. I’m asking 

6 you and your group to put some weight on their 

7 recommendations on the medium voltage liquid filled 

8 as well. Thank you.

9 MR. PARKER: Andrew.

10 MR. DeLASKI: I’m going to talk liquid 

11 filled off line with you, Ray. Let’s have this 

12 conversation off line. For this one, yeah, Steve, 

13 we noticed some of the same changes to the LCC that 

14 -- the latest. So, we’re a little puzzled by them, 

15 frankly, because what happened relative to the last 

16 analysis that we used as the basis for our 

17 conversation on the phone call, is that the LCC got 

18 worse for design line 11, and it got better for 

19 design line 12. So they moved in opposite 

20 directions based on using the 2011 steel prices 

21 instead of using the 2010 steel prices. So here we 

22 are back to steel prices again. 

23 And as I understand it, what’s primarily 

24 driving it is base case, because steel prices went 

25 down to base case by 30 percent of their ... And you 
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1 just have a different shape to the curve. So this 

2 is the 2011 data. The 2010 data is what we based 

3 our recommendation on last time. We didn’t have the 

4 benefit of this data at the time. I suspect, you 

5 know, from some of the comments made by the 

6 Department or the consultants earlier, that in the 

7 final analysis some sort of averaging of these 

8 prices is going to be necessary and you’re going to 

9 end up with results that are not what we’re looking 

10 at right here. But it is the proposal. We have the 

11 LCC -- it makes it hard to convert, so -- yes, 

12 doesn’t it. 

13 So again, we based our recommendation on 

14 the last LCC 2010 prices. If you do an averaging, 

15 you’re going to come out -- a five year moving 

16 average, I don’t know if that’s a right number or 

17 not, but you’re going to come up with something. 

18 That was what we used in 2007. Even another result, 

19 I’m comfortable with the manufacturers’ proposal in 

20 this case.

21 MR. PARKER: We also have to remember that 

22 we’re comparing apples and oranges in the LCC. 

23 We’re comparing a computer model and an optimization 

24 model done by analysts who are outside the industry 

25 to results that we have --
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1 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

2 appreciate that. Again, I was looking at this 

3 because I heard yesterday, I hope I’m not mistaken, 

4 that DOE wanted to use 2011 data for their decision5 making.

6 MR. DeLASKI: Yeah, and --

7 MR. ROSENSTOCK: That’s what I heard, 

8 that’s why I’m looking at this -- this one here 

9 today. That’s why.

10 MR. PARKER: Let’s take a short break and 

11 reconvene in 15 or 20 minutes.

12 (Whereupon, at 11:10 a.m., the meeting was 

13 off the record for a 32 minute period, until 11:42 

14 a.m.)

15 MR. PARKER: So we have 45 minutes before 

16 our scheduled break at 12:30. At 12:30 we will 

17 adjourn, approximately, and those that are coming 

18 back for the low voltage talks will have an hour and 

19 a half for lunch -- the low voltage talks at two, 

20 here.

21 On medium voltage, I think we’ve had a 

22 very, very positive and very constructive 

23 discussion. I appreciate the hard work on 

24 everybody’s part that has joined in this. We have 

25 proposals on the table. We have discussed them. 
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1 What I’d like to do now is basically direct a straw 

2 poll on each of the proposals that have been put 

3 forward.

4 Let’s see just where -- again, this is not 

5 a permanent thing. This is not the final -- the 

6 final say. This is just --

7 MR. ROSENFELD: Richard, this is Art 

8 Rosenfeld. I simply can’t hear you.

9 MR. PARKER: Oh, sorry. This is not the -

10 - this is not intended as the final word on this. 

11 I’ve heard from stakeholders around the table that 

12 there are still are some concerns about the current 

13 DOE analysis, and there is a sense, I think, on all 

14 sides, that the DOE analysis can be refined, based 

15 upon input from people here, to come into more align 

16 with what we’re hearing from the source of that 

17 analysis anyway, which is the transformer 

18 manufacturers and steel people about what is 

19 possible.

20 I also want to emphasize that the 2011 LCC 

21 results that you’ve got were not optimized designs, 

22 and they were done by an optimization process --

23 excuse me -- a selection process by consultants who 

24 are not in the actual industry themselves, so I 

25 think wherever there is a conflict between a theory 
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1 and the reality, the reality should prevail. The 

2 question is, can we come up with an analysis that 

3 reflects that, and I feel pretty confident that we 

4 can.

5 At the same time, I know that people came 

6 with a certain understanding, certain instructions 

7 from their management, and they need to go back to 

8 their management and get further authorization 

9 before they can move from that. 

10 Final Discussion and Straw Poll

11 So, with that in mind, what I’d like to do 

12 is starting off with the NEMA proposal, let’s have a 

13 show of hands for that. If we could, before we 

14 vote, if John Caskey could just in a nutshell, 

15 review the proposal one last time so it’s up in 

16 everybody’s mind, we will hear that and then we will 

17 conduct our straw poll.

18 MR. CASKEY: Okay. This is John Caskey, 

19 NEMA. I think what I’ve got here is: 

20 • For design line 9, we’re recommending EL 1.5

21 • For design line 10, EL 2.0

22 • For design line 11, 2.0

23 • For design line 12, 3.0

24 • For design line 13, we’re going to work and try 

25 and resolve that issue, but for the higher 
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1 BILs, we want basically ten percent more losses 

2 allowed than under the DL-12. We’re not sure 

3 how that relates to an EL level yet. We need 

4 to work on that.

5 MR. PARKER: When you say “higher BILs” do 

6 you have a --

7 MR. CASKEY: Above 95.

8 MR. PARKER: Above 95. Thank you.

9 MR. CASKEY: So the things that we still 

10 need to work on is what I just said about the higher 

11 BILs, the single-phase issue that is not a direct 

12 calculation from -- or a simple normalization from 

13 three-phase to a single-phase. We need to provide 

14 for the fact that it is more difficult to produce 

15 one than the other. And the third area that -- I 

16 think everybody agreed to work on that -- and the 

17 third area deals with the smaller KVAs, and 

18 particularly in the 15 -- below 300 KVA and look at 

19 trying to make sure that we adjust for that because 

20 the manufacturers reported that it’s -- in some 

21 areas it’s more difficult to go beyond the EL-1. So 

22 those are the --

23 MR. PARKER: Below 300 KVA is the 

24 threshold?

25 MR. CASKEY: Yes.
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1 MR. PARKER: Okay. Any other clarifying 

2 question before we go on and vote?

3 MR. ROSENSTOCK: Quick process? Steve 

4 Rosenstock, EEI. Are we going to vote on all the 

5 design lines as one package, is that the idea, or 

6 separate design lines?

7 MR. PARKER: Why don’t we vote on them as 

8 a package, I think that would be much simpler, thank 

9 you. All in favor? (Counting.) Twelve. Opposed? 

10 (Counting) Seven. Abstain? One.

11 MR. CYMBALSKY: Two. I’ll abstain for 

12 Art.

13 MR. PARKER: Okay. Two abstain. So, 

14 seven no’s, twelve in favor, two abstain. Okay. So 

15 I think what we should do, both for medium voltage 

16 and for liquid immersed is move forward.

17 MR. ROSENSTOCK: Can we take another straw 

18 vote here?

19 MR. PARKER: What’s that?

20 MR. ROSENSTOCK: Can we take other votes 

21 here?

22 PARTICIPANT: Two more proposals.

23 MR. PARKER: Yes, sorry, sorry, sorry. 

24 Yes. Please. Steve, do you have any proposals.

25 MR. ROSENSTOCK: Well, I -- Steve 
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1 Rosenstock, EEI. There are two proposals. One for 

2 EL-1 across the board, and then EL-1.5 across the 

3 board. That’s what I heard earlier.

4 MR. PARKER: Okay. Ray, would you like to 

5 state your proposal?

6 MR. POLINSKI: Ray Polinski, ATI 

7 Allegheny. And as I said, for now I’d just like to 

8 vote on the first proposal that I went out there, 

9 which was EL-1 across the board for design lines 

10 nine through 13.

11 MR. PARKER: Okay. Thank you. Since we 

12 only had two proposals, I had sort of assumed that 

13 the results of holding a straw poll on the second 

14 would be the inverse of the first, but I’m perfectly 

15 happy to go through the exercise. 

16 MR. PARKER: Okay, Steve?

17 MR. ROSENSTOCK: I’d like to take a straw 

18 vote on EL-1.5 across the board. 

19 MR. PARKER: All in favor?

20 PARTICIPANTS: One point five.

21 MR. PARKER: One point five across the 

22 board. All in favor? (Counting.) Seven. Okay. 

23 All opposed? Vijay, you’re not on the committee 

24 still. (Counting.) Seven. Abstains? (Counting.) 

25 Eight. Eight, I keep forgetting Art.
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1 Thank you. Any other proposals? Okay. 

2 One of the shortcomings of straw polls is that, or 

3 any kind of polls, or any kind of polling process is 

4 that they don’t register an intensity of preference, 

5 and I do get a sense that there is a lot more 

6 flexibility around the table in the medium voltage 

7 dry than in the liquid immersed. But I also get a 

8 sense that there’s still some flexibility in the 

9 liquid on the decision that we had last night after 

10 the meeting --

11 (Discussions off mic)

12 Proposal for Next Step

13 MR. PARKER: So, what I would propose is 

14 that moving forward first we recognize that we are 

15 out of time in terms of meetings. We have spent a 

16 great deal of time getting the analysis to date, and 

17 defined, and getting to understand it better, and 

18 that process continues. I think we can actually 

19 enter the phase where plenary meetings are less 

20 useful than smaller group meetings, caucuses, that 

21 we can do by telephone conference calls, and over 

22 the next few weeks, hopefully couple of weeks, as 

23 people talk to each other and reflect on their 

24 positions and the data continues to emerge and 

25 evolve, and the analysis evolves, I am hopeful that 
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1 we can bridge some of the differences, both in 

2 liquid immersed and medium voltage that we’ve 

3 encountered so far. 

4 And so I think that that might be a useful 

5 way to proceed. We have had a good experience so 

6 far in this group with telephone conference calls in 

7 both the medium voltage and low voltage space --

8 calls -- those were productive calls. I suggest we 

9 move forward if we don’t have meeting space reserved 

10 that we can be physically present. So that’s what I 

11 would propose to do. If you all -- I think we need 

12 to -- we’re all curious about, you know, where DOE 

13 is in this process and , you know, I think we’re 

14 going to need to explore what -- where people --

15 where stakeholders are, including the Department at 

16 this stage, in a ... way, an exploratory way, and hear 

17 from everybody about what they can give, what they 

18 can’t give, and what progress we can make, if any.

19 So, I would propose that we move forward 

20 in that way in the next couple of weeks, and then 

21 take stock of where we are. Eric.

22 MR. PETERSEN: Eric Petersen, AK Steel. I 

23 don’t know if you want me to say this or not, 

24 Richard, I’ll just throw it out. But we have had a 

25 change in our position at AK Steel as to how we 
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1 voted yesterday, would you like me to bring that to 

2 the table, or you just want to deal with it on the 

3 individual basis, considering where everything is 

4 at. Obviously, one vote wouldn’t make a change in 

5 consensus, but -- if you’d like me to speak to it, I 

6 can tell you how our vote would change from 

7 yesterday.

8 MR. PARKER: That would be very helpful. 

9 Go ahead.

10 MR. PETERSEN: Okay. Yesterday, we voted 

11 that --

12 MR. ROSENFELD: Richard, one point -- this 

13 is Art Rosenfeld. I just understood my phone was on 

14 mute and I abstained on all three votes, and 

15 particularly since nobody could hear me, but just 

16 for the record, I abstained.

17 MR. PARKER: Thank you, Art. I think John 

18 anticipated your position and entered your position 

19 on your behalf.

20 MR. ROSENFELD: Thank you. Sorry I messed 

21 up. I’ll shut up again.

22 MR. PARKER: Talk whenever you feel like 

23 it, Art. You’re most welcomed. Go ahead.

24 MR. PETERSEN: Eric Petersen, AK Steel. 

25 I’d like to comment that as we had some discussion 
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1 last night in regards to our position and how we 

2 voted yesterday. If we were to vote again today, we 

3 would change our position, versus on how we voted 

4 yesterday, and I think the key that we see is we are 

5 interested in identifying an efficiency level at 

6 which grain-oriented electrical steel has an 

7 opportunity to compete against amorphous metal, and 

8 that there is plenty of opportunity for supply for 

9 the transformer manufacturers. That’s the key point 

10 that we are looking for.

11 In trying to find exactly how far we can 

12 go, we are very confident that there absolutely is a 

13 cliff that you could result into a essentially 

14 monopoly position of amorphous metal. So our 

15 concern is understanding how far you can go until 

16 you hit that cliff. Our modeling capability cannot 

17 get us there, so we are going to be dependent upon 

18 those people that are the experts, that being the 

19 transformer manufacturers. The transformer 

20 manufacturers, as we communicate with them, have 

21 communicated to me that they are interested in that 

22 same goal, in providing a business model that 

23 insures that they have a competitive supply base 

24 which insures that steel has an opportunity to 

25 produce.
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1 While we recognize that the DOE/Navigant 

2 modeling has some issues, this model of liquid 

3 immersed is certainly better than what we just 

4 talked about because of the efforts that have been 

5 made on the transformer manufacturers part. I want 

6 to thank the transformer manufacturers for spending 

7 that amount of time. So, in our perspective in 

8 trying to understand where we can go, we’re going to 

9 depend upon our customers, the ones that are the 

10 experts, the transformer manufacturers are the ones 

11 that can define, amidst all this modeling, all these 

12 technical issues, where they can build a transformer 

13 that insures that there is a good supply amongst the 

14 product base. 

15 So with that in mind, we would change our 

16 vote from what we provided yesterday to move to the 

17 NEMA vote, which was the one, zero, one, one, one, 

18 recognizing that again, as I stated, they’re the 

19 experts, and I think it also provides us an 

20 opportunity to improve. It’s not a step backwards. 

21 It is a step forward, and also puts a -- what I 

22 call, mitigated safeguard in regards to this 

23 refurbishment issue. 

24 It’s been commented numerous times. I 

25 think it has been justified as a question. I agree 
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1 that it has not been justified as an actual reality 

2 of where it’s going to go, but it certainly a 

3 question, and moving to the NEMA level will allow an 

4 opportunity to increase, provide a stable supply, 

5 and not go so far that you have to be concerned 

6 whether or not you’re going to, for lack of a better 

7 analogy, release the lion and then determine are you 

8 going to go find the gun or some way of dealing with 

9 it. 

10 We have not been able to define that there 

11 is a clear methodology of dealing with a means of 

12 regulating a refurbishment industry. Without that 

13 in place, recognizing the significant diminishment 

14 it could handle, I would strongly recommend that we 

15 take NEMA’s recommendation as it gives time, then, 

16 for efforts to be made, of handling a regulatory 

17 mechanism by which you can insure that refurbishment 

18 does not diminish the efficiency standards and 

19 benefits we would gain from a level that is well 

20 beyond NEMA’s standard.

21 So that’s the position that we have come 

22 to in regards to where we would go.

23 MR. PARKER: Thank you, Eric. Any other 

24 comments on this -- any other comments on the straw

25 poll we took yesterday? Okay, does the premise that 
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1 I have suggested make sense to the group with regard 

2 to the liquid immersed, first? And secondly with 

3 regard to medium voltage dry type? Steve.

4 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

5 think what you’re saying does make sense, but if 

6 there’s going to be off-line conversations, to use ... 

7 word, let’s just say we’re shifting to e-mail 

8 traffic. I think it would help if, you know, 

9 because I think people want to continue the 

10 conversation -- if we could get some guidance in 

11 terms of when we decide on some numbers, would it be 

12 fair to DOE and the analysts if they have to retype 

13 all the numbers based on, say, a negotiated number -

14 - what would be a fair deadline to get them, say --

15 why not just ask for -- okay, if DOE has to publish 

something by February 1st

21 MR. PARKER: Well, that’s a fair question. 

22 I think the best way to answer that is to recount a 

23 conversation that I had with Phil Harter last night, 

24 who I’ve been consulting regularly throughout this 

25 process, and who invented the concept of negotiated 

16 , what’s our real deadline 

17 in terms of -- if you’re going to get numbers here 

18 to be fair to the analysts and to DOE in terms of 

19 writing up something? In my mind, that would be 

20 helpful to all parties.
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1 rulemaking and has done any number of these in the 

2 past, ending up successful. But I said, Phil, we 

3 seem to be pretty stuck on liquid immersed. He 

4 said, well, how long has it been since you -- since 

5 everybody was at the table and took the first straw 

6 poll? And I told him, 30 minutes. So we had taken 

7 a long time to get where we are, but we have not 

8 yet, you know, I think reached a point where 

9 reasonable people would say we can’t make any 

10 further progress. In fact, I think based upon the 

11 discussions of last night and this morning, we are 

12 far from that point. So that’s my proposed 

13 continuing the dialogue.

Now, in terms of timing, February 1st 14 is 

15 rapidly approaching. In order for the OMB to get 

16 their product reviewed and advanced, they would need 

something by January 1st 17 at the latest, as I 

18 understand. And the question is, what do you do 

19 given those time frames? One possibility that I 

20 have discussed with Dan Cohen who was on the 

21 webinar, is the idea of the Department publishing a 

22 NOPR on schedule that would contain all the stuff 

23 that a NOPR normally contains, and all of the -- all 

24 the elements of the standard one would need, but 

25 would contain, basically, brackets for those areas 
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1 that we have decided, and that we’re saying we will 

2 propose these levels, we’re taking comment on them, 

3 but we haven’t taken a firm position. 

4 This doesn’t mean that the Department will 

5 state informally, off-line, which way they’re 

6 leaning. Individuals at the Department won’t, but 

7 in terms of the NOPR, it doesn’t have to be a 

8 proposed rule. As a professor of administrative 

9 law, very familiar with the APA, as is Dan Cohen, 

10 we’ve had this discussion. Everyone is comfortable. 

11 What the APA calls for is a Notice of Proposed 

12 Rulemaking. The idea that you actually fill in a 

13 draft rule and file that is a matter of custom. It 

14 is not a matter of law. It’s not required. And so 

15 the NOPR can be a document which leaves open blanks 

16 which this body will fill.

17 Now, that said, there does still need to 

18 be a deadline. Because what is not flexible is the 

19 October 1 date for a final rule, and there has to be 

20 time for public notice and comment before then. So 

21 we can have a protracted process, and will have a 

22 protracted process if this drags on into the spring. 

23 At the same time, we don’t have to be like deer in 

the headlights with regard to the February 1st 24

25 deadline.
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1 That’s my understanding from the 

2 Department. John, is that acceptable with the DOE 

3 perspective? John is saying yes. So this also 

4 raises the question from the standpoint of the 

5 advocates in the corner of the deadline, so Andrew 

6 has his hand in the air, and I will call Andrew to 

7 respond to that.

8 MR. DeLASKI: It’s a novel concept. 

9 (Laughter.) And I’m not questioning it in terms of 

10 law. I know that ... has sometimes proposed rules 

11 with multiple options, but restricting blanks 

12 strikes me as being outside the scope of Department 

13 practice in past years. So I’m concerned about this 

14 notion of just blanks. Now options --

15 MR. PARKER: No, no. I’m sorry. I did 

16 not mean -- when I said brackets, I didn’t meet to 

17 populate those brackets with blanks, I meant to 

18 populate them with multiple options, yes.

19 MR. DeLASKI: And I see scaling as well, 

20 so I think this is something that we’re going to 

21 take under consideration. The Department issues a 

22 proposed rule, an opportunity for public comment on 

23 that proposed rule. The problem with one, we’re not 

24 the whole world at this table. There are other 

25 comments or proposals, and there’s a schedule and a 
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1 timeframe for that in the process that’s as 

2 important as well. So we’ll take it under 

3 consideration, but it’s not something we’re prepared 

4 to sign off on as a process question, I think, 

5 sitting here today. It’s new -- it’s a brand new 

6 idea.

7 MR. PARKER: Tim, did you want to comment?

8 MR. BALLO: Sure, the idea of brackets --

9 I guess I don’t see the harm in proposing a standard 

10 that reflects the Department’s actual thinking at 

11 this point, and then the door is always open to 

12 modify that, you know, in the future, based on the 

13 comments received. So I don’t see why this NOPR 

14 would have to be different from regular practice. 

15 Also, at least with regard to the low 

16 voltage dries, the APA is not the only criteria that 

17 applies. There’s the six year provision in APCA 

18 (ph) provides that the Department must issue a 

19 Notice of Proposed Rulemaking, including new 

20 proposed standards. So I think at least for the low 

21 voltage dries, you do have to propose something 

22 specific.

23 As far as the court case and --

24 MR. PARKER: Tim, the low voltage dries is 

25 not even subject to the law suit, so --
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1 MR. BALLO: Yeah, but -- anyway. AS far 

as the February 1st

10 If others see things differently, I’m 

11 ready to discuss the possibility of further 

12 extension. I can’t say that I would agree for it.

2 deadline, I think our interest is 

3 primarily in getting something out as a proposal, 

4 and I don’t see that as a roadblock to any consensus 

5 process that would develop, or joint comments that 

6 would endorse something that all or most of the 

7 parties involved agree on. I don’t think that a 

8 proposed rule would foreclose adoption of a final 

9 rule reflective of what we could agree on.

13 MR. PARKER: I’m not sure that we have to 

14 decide here today what the deadline is, or how a 

February 1st

20 Another option would be for the Department 

21 just to issue their NOPR with the brackets filled 

22 in. It has the effect of heavily entrenching 

23 positions, but it is a notice and it is subject to 

24 further comment, and it can be changed. So it 

25 doesn’t lock anybody in. So that would be another

15 NOPR would be worded. I’m not sure it’s 

16 our interest to try to micromanage the future that 

17 way. I offered that as an option, as a sort of 

18 worst case option, should that become necessary, and 

19 should it be deemed desirable. 
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1 option. And I don’t think we necessarily have to, 

2 today, choose between those options. 

3 The point that I was simply trying to make 

4 was that there are a variety of ways that we could 

handle the February 1st

7 MR. DeLASKI: Just to follow on. I mean 

8 the parties to the suit are -- or at least some of 

9 the leads to the suit -- the parties to the suit are 

10 around the table, so it strikes me that if there is 

11 a consensus that emerges between now and hopefully 

12 relatively soon, the sooner the better -- but if a 

13 consensus emerges, then I think flexibility along 

14 the dates could be more likely. So the two things 

15 are linked. It isn’t like we’re talking about ... the 

16 law suit is not ... outside this room. So if we’re 

17 not making progress, then I think the interest in 

18 extending the deadline is -- goes away. We’ve got 

19 to keep on for further process.

5 deadline that would allow us 

6 to continue our talks beyond today. That was my --

20 MR. PARKER: And Andrew points to a third 

21 option, which is that if we are making progress, and 

22 if there is a view that more time would be 

23 necessary, that an option would be to go to the 

24 court and provide another 30 days or whatever he 

25 thinks is appropriate, based on what it is the 
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1 process ... up there. So we have not one but three 

2 different ways of handling -- of answering Steve 

3 Rosenstock’s concern.

4 MR. CYMBALSKY: Hi, John Cymbalsky, DOE. 

5 I just want to -- what Richard mentioned is an 

6 option and no decision on how the NOPR will be 

7 written has been made at this time. It’s just an 

8 option that’s been used in other agencies. Andrew 

9 is correct, we, as far as I know, have never used 

10 sort of pure all the TSL levels. We haven’t picked 

11 one yet. We haven’t done that before. It’s been 

12 done in other agencies, as far as I am aware. No 

13 final decision by the Department has been made on 

14 how we’re going to write the NOPR at this time.

15 MR. PARKER: Any other comments on that? 

16 So is there agreement to keep talking in good faith, 

17 and not just talking, but negotiating and moving in 

18 a somewhat different format, but hopefully with a 

19 clear purpose and still with ex... timeframe? All in 

20 favor? Opposed? Well, we’ve reached consensus on 

21 one thing. Great. With that, you all deserve 

22 lunch. Let’s break at 12:15. 

23 For the people who are leaving us today, 

24 thank you so much for your involvement in this 

25 process, and it’s been a very, very helpful and 
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1 productive journey. We still have a ways to go, but 

2 I’m hopeful that with good faith and hard work, we 

3 can get there. 

4 MR. BALLO: Richard, I would just ask, 

5 would folks find it helpful to tentatively schedule 

6 another call in a couple of weeks to check in on ... 

7 MR. PARKER: That might be a good idea. 

8 I’m not sure that -- I guess my instinct was to sort 

9 of let’s caucus and let’s talk to people 

10 individually and see how things are going and at 

11 what speed. Calls may be set much more easily than 

12 me --

13 MR. BALLO: Around the holidays --

14 MR. PARKER: That may be true. I’m open 

15 to the idea of scheduling a call if people want to 

16 do that. You’re talking about a plenary call now, 

17 right? For the entire group? Anybody have a 

18 calendar with them?

19 (Discussion off mic)

20 MR. PARKER: Great. Let’s see. What 

about eleven o’clock on the 14th

23 MR. ROSENSTOCK: Yes?

21 ? I’ll just throw a 

22 number out at random.

24 MR. PARKER: What’s that?

25 MR. ROSENSTOCK: Are you asking for yes 
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1 votes for that time period?

MR. PARKER: Eleven o’clock on the 14th

4 MR. CASKEY: I can’t --

2 , 

3 yes. All in favor.

5 MR. PARKER: Anybody can’t make that? You 

6 cannot make that. John, can you propose an 

7 alternative?

8 MR. CYMBALSKY: I’m looking for my --

9 MR. PARKER: No, I’m looking to John 

10 Caskey, sorry. He said he couldn’t make it.

11 MR. CASKEY: That’s two weeks from 

12 yesterday?

13 MR. PARKER: Right. Again, I think we 

14 should approach this with the idea that this is 

15 notional, the time, because I think what’s more 

16 important is to -- is to stage a plenary call at a 

17 time when we really, you know, are at a stage where 

18 people may have come together in their minds with 

19 small group meetings. So I had some reservations 

20 about locking us into a time, but I can see the 

21 attraction on the other hand, to try to keep the 

22 train moving.

23 PARTICIPANT: A place holder.

24 MR. PARKER: Yeah. John Caskey, did you 

have a -- is there another time on the 14th 25 or is the 
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1 whole day --

2 MR. CASKEY: The whole day is out. And 

even for the 15th

6 MR. PARKER: Okay. 

3 , I’ve got other like management 

4 meetings, but I don’t have the agenda yet to know 

5 what time I would need to be in them.

7 MR. CASKEY: But Jim can fill in for me. 

8 Jim is my substitute if for some reason I can’t make 

9 it. Jim Creevy.

10 MR. DeLASKI: I would suggest to go to the 

11 following week, on Monday or Tuesday.

12 MR. PETERSEN: Eric.

13 MR. PETERSEN: I guess my point is we 

14 talked about Wednesday through Friday months ago as 

15 tentative, and I’ve got those dates available. I 

16 guess my recommendation would be to go with those 

17 three days as we identified those some time ago. 

18 Either one of them, Wednesday, Thursday, or Friday 

19 is good by me.

20 MR. DeLASKI: I’m out Thursday, Friday. 

21 Not out, I’ve got other commitments.

22 MR. PARKER: What about Wednesday -- I’m 

23 sorry my calendar is not on here -- what date is 

24 Wednesday?

25 PARTICIPANT: Fourteenth.
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1 MR. CASKEY: I can’t do it. Jim, can you 

2 cover for me?

3 MR. PARKER: Okay. So Jim can join us on 

the 14th 4 , then? Okay. Time. Eleven o’clock goes 

5 into the lunch hour and it might go a little more 

than an hour, shall we say ten o’clock on the 14th

7 MR. DeLASKI: Yes, west coasters -- so one 

o’clock? One o’clock on the 14

6 ?

th

9 MR. DeLASKI: I can’t do that.

8 .

10 (General discussion on time.)

11 MR. PARKER: Okay. Eleven to one on the 

14th

13 MR. SMITH: Richard, Bob Smith, Federal 

14 Pacific. Before we adjourn, may I ask you a 

15 question?

12 .

16 MR. PARKER: Sure.

17 MR. SMITH: You made an interesting 

18 comment a while back, stating that while the votes 

19 for the medium voltage dry type were somewhat 

20 similar that we saw in the medium voltage liquid 

21 meeting, that the intention of the DOE of trying to 

22 come together was much closer with the medium 

23 voltage dry types. And I am wondering if it would 

24 be possible for you or another appropriate person to 

25 visit with the people who voted no and ask them 
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1 under what conditions would they change their vote 

2 to a yes. That those conditions may be better 

3 information from Navigant. It may be that M4 has to 

4 be a viable steel for all of the efficiency levels, 

5 but if you or the appropriate person could do that 

6 with those that are voting no, I think that would 

7 help us get our issues resolved much quicker.

8 MR. PARKER: Thank you, Bob, that’s why 

9 they gave me the small bucks. Yes, I plan to do 

10 that.

11 MR. SMITH: That would be great. If you 

12 could share with the rest of us that are supporting 

13 the NEMA proposal, that would be terrific.

14 MR. PARKER: Thanks, Bob. Anything else 

15 before we adjourn? For those leaving us, bon 

16 voyage, and thanks. For those rejoining us for low

17 voltage, in the afternoon, we’ll reconvene here at 

18 two. Enjoy your lunch.

19 (Whereupon, at 12:18 p.m., the meeting in 

20 the above captioned matter was adjourned.) 

21

22

23

24

25
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REPORTER'S CERTIFICATE

This is to certify that the attached proceedings 

before:

U.S. DEPARTMENT OF ENERGY

In the Matter of:

MEETING of the MV WORKING GROUP

Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law 

Judge or the Agency.

Further, I am neither counsel for or related to 

any party to the above proceedings.

 Official Reporter

Wendy Greene 

Dated: December 6, 2011