To: Distribution Transformers Docket, EE-RM/STD-00-550, RIN 1904-AB08

From: Michael Scholand, Navigant Consulting Date: November 1, 2006 Re: Record of phone conversation with ERMCO

This memo serves to record that Barclay Gibbs and Michael Scholand both of Navigant Consulting contacted Alan Wilks, Vice President of Engineering at ERMCO Distribution Transformers. The purpose for this call was to ask for clarification on their comment to DOE dated October 11, 2006, submitted by Mr. Wilks. Mr. Gibbs had contacted the Department of Energy and secured approval for this phone call from DOE General Counsel.

In their October 11th comment, ERMCO raised concern over the design voltages that were used by the DOE in the engineering analysis. ERMCO wrote that they "made a startling discovery." They found that "[m]any of the voltage combinations that are commonly manufactured cannot meet the TSL4 level." ERMCO went on in their letter to indicate that while the voltage ratings used in the engineering analysis were indeed typical, the physical requirements of other voltage combinations may not be able to achieve the TSL4 efficiency level. ERMCO expressed concern that if the DOE adopted TSL4 as some stakeholders had suggested, certain voltage combinations that are being purchased today could no longer be manufactured.

NCI asked ERMCO to provide guidance concerning voltage combinations and/or winding configurations for the five liquid-immersed representative units analyzed (50kVA, 25kVA, 500 kVA, 150kVA and 1500kVA) that ERMCO believes would have difficulty achieving TSL4. NCI asked that ERMCO provide that information in a supplemental written comment submitted to DOE as part of the docket. NCI indicated that although the comment period had closed, DOE was interested in receiving this clarification on their comment and would work to take this new information into consideration. To: From: Date: Re: Distribution Transformers Docket, EE-RM/STD-00-550, RIN 1904-AB08 Michael Scholand, Navigant Consulting November 1,2006 Record ofphone conversation with ERMCO 

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This memo serves to record that Barclay Gibbs and Michael Scholand both ofNavigant Consulting contacted AlanWilks, Vice President ofEngineering at ERMCO Distribution Transformers. Thepurpose for this call was to ask for clarification on their commentto DOE dated October 11,2006, submittedbyMr. Wilks. Mr. Gibbs had contacted the Department ofEnergy and secured approval for this phone call from DOE General Counsel.

Intheir October 11 th comment, ERMCO raised concern overthe design voltages that

were used bythe DOE in the engineering analysis. ERMCO wrote that they "made a startling discovery." They found that "[m]any ofthe voltage combinations that are commonly manufactured cannot meet the TSL41evel." ERMCO went on in their letter to indicate that while the voltage ratings used in the engineering analysis were indeed typical, the physical requirements ofother voltage combinations may notbe able to achieve the TSL4 efficiency level. ERMCO expressed concernthatifthe DOE adopted TSL4 as some stakeholders had suggested, certain voltage combinations that are being purchasedtoday couldno longer be manufactured.

NCI asked ERMCO to provide guidance concerning voltage combinations and/or winding configurations for the five liquid-immersed representative units analyzed (50kVA, 25kVA, 500 kVA, 150kVA and 1500kVA) that ERMCO believes wouldhave difficulty achieving TSL4. NCI asked that ERMCO provide that information in a supplemental written comment submittedto DOE as part ofthe docket. NCI indicated that although the commentperiodhad closed, DOE was interested inreceiving this clarification on their comment and would work to take this new information into consideration.