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UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY 

MEETING of the LV 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: 

Tim Ballo

Earth Justice

1625 Massachusetts Avenue

Suite 702

Washington, DC 20036

Scott Beck

Lakeview Metals

Chris Brown

Cogent Power

Ned Brush 

Consultant

John Caskey 

National Electrical Manufacturers Association

Scott Choinski

National Electrical Manufacturers Association

1300 North 17th

Suite 1752

Street

Rosslyn, VA 22209

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

Tom Eckman

Northwest Power and Conservation Council

Gary Fernstrom

Pacific Gas & Electric Company

13055 Parkhurst Dr

Oakland, CA 94619
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Robert Greeson

Federal Pacific Company

Don Lewis

Alconex

Dave Millure

Metglas Incorporated

440 Allied Drive

Conway, SC 29526

Wes Patterson

ABB, Inc.

Thomas Patzner 

Schneider Electric

Eric Petersen 

AK Steel

Eduardo Robles

Eaton Corporation

Mahesh P. Sampat

EMS Consulting

1180 Brookview Dr

Athens, GA 30606

Jerry Schoen

AK Steel Corporation

705 Curtis Street

Middletown, OH 45043

Vijay Tendulkar

Onyx Power

Participants from DOE:

John Cymbalsky

Jim Raba
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Participants from Navigant/LBL:

Brian Coffey

Navigant

Mike Rivest

Navigant

Matt Nardotti

Navigant Consulting

Chris Bolduc

Lawrence Berkley National Laboratory

Berkeley, CA 94720

Katie Coughlin

Lawrence Berkley National Laboratory

Luo Zhimei (webinar)

Navigant Consulting

Webinar Attendees

Jerry Allen

Metglas, Inc.

Jay Ballard

Schneider Electric

Kenneth Harden

Schneider Electric

Brian Kaja

General Electric

Chad Kennedy

Schneider Electric

Philip Ling

Powersmiths International Corp

Richard Lyke

AK Steel
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Dhiru Patel 

Hammond Power Solutions Inc.

John Rosetti

Memphis Light Gas and Water

Bob Smith

Federal Pacific
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AGENDA

 ITEM PAGE

Welcome, Mr. Parker 89

Self-Introductions 89

Proposals

Advocates: Mr. Delaski 95

Discussion of Data Center Transformers

Mr. Tendulkar 145
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1 9:24 a.m.

3 MR. PARKER: Okay. Welcome everyone for 

4 day two for some of us, and day three for others of 

5 us. It’s been a long run, but I think it’s been 

6 very productive discussion, all three days, and I 

7 hope we can make good progress today. Today’s going 

8 to be about discussing proposals. I think from 

9 talking to various parties, there is a lot of 

10 interest in getting to yes all around the table, and 

11 I’m optimistic that we can do that, if not at this 

12 meeting, soon thereafter. Let’s go around the table 

13 and introduce ourselves, then we’ll go around the 

14 back and we’ll have the people on the wall introduce 

15 themselves, and then we’re going to get started. . 

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

16 Self-introductions

17 MR. PARKER: I’m Richard Parker, 

18 facilitator, University of Connecticut Law School.

19 MR. BALLO: Tim Ballo, Earth Justice.

20 MR. ROY: Robin Roy, Natural Resources 

21 Defense Council.

22 MR. FERNSTROM: Gary Fernstrom, PG&E 

23 representing PG&E, the Southern California Edison 

24 Company and Semper Utilities, and our 30 million 

25 customers. 
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1 MR. DeLASKI: Andrew DeLaski, Appliance 

2 Standards Awareness Project.

3 MR. BECK: Scott Beck, Lakeview Metals.

4 MR. MILLURE: Dave Millure, Metglas.

5 MR. PETERSEN: Eric Petersen, AK Steel.

6 MR. GREESON: Robert Greeson, Federal 

7 Pacific Transformer.

8 MR. CASKEY: John Caskey, NEMA.

9 MR. TENDULKAR: Vijay Tendulkar, Onyx 

10 Power.

11 MR. ROBLES: Eduardo Robles, Eaton 

12 Corporation.

13 MR. PATZNER: Thomas Patzner, Schneider 

14 Electric.

15 MR. CYMBALSKY: John Cymbalsky, DOE.

16 MR. RIVEST: Mike Rivest, Navigant 

17 Consulting.

18 MR. PATTERSON: Wes Patterson, ABB.

19 MR. SAMPAT: Mahesh Sampat, EMS 

20 Consulting.

21 MR. BRUSH: Ned Brush, consultant.

22 MR. BROWN: Chris Brown, Cogent Power.

23 MR. LEWIS: Don Lewis, Alconex.

24 MR. SCHOEN: Jerry Schoen, AK Steel. 

25 MR. LYKE: Rick Lyke, AK Steel. (phone)
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1 MR. CHOINSKI: Scott Choinski, with NEMA.

2 MR. NARDOTTI: Matt Nardotti, Navigant.

3 MR. BOLDUC: Chris Bolduc, Lawrence 

4 Berkley National Labs.

5 MS. COUGHLIN: Katie Coughlin, Lawrence 

6 Berkley National Labs.

7 MR. CREEVY: Jim Creevy, NEMA.

8 MR. COFFEY: Brian Coffey, Navigant. 

9 MR. RABA: Jim Raba, Department of Energy.

10 MR. PARKER: Okay, on the phone?

11 MR. LING: Philip Ling from Powersmiths.

12 MR. ALLEN: Jerry Allen, Metglas.

13 MR. LYKE: Richard Lyke, AK Steel.

14 MR. PARKER: Anyone else on the phone?

15 MR. LING: I just want to check. Phil 

16 Ling from Powersmiths, can you hear us?

17 MR. PARKER: Yes, we can hear you.

18 MR. LING: Okay, Richard, thanks.

19 MR. PARKER: Everything else okay?

20 MR. LING: Some of the people are more 

21 soft-spoken that others, but if everybody speaks up, 

22 it sounds great.

23 MR. PARKER: Okay. Good. Thank you. 

24 Anybody else on the phone? Okay. Welcome. 

25
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1 Proposed Agenda

2 MR. PARKER: So the agenda for today is to 

3 discuss proposals and see how far we can get in 

4 arriving at an agreement on standard levels, 

5 particularly for design lines seven and eight, I 

6 believe, which are the bulk of the market.

7 I understand from the advocates that 

8 they’d like to caucus and discuss their proposal --

9 Excuse me, if you’re on the phone, could 

10 you please mute your phones until you wish to speak. 

11 Thank you. 

12 And in general I think today will be not a 

13 plenary gab-fest as we’ve had in previous meetings. 

14 I think the most productive way to use the day would 

15 be for people to put forward proposals, take a 

16 break, let people discuss the different groups 

17 discuss their response and then reconvene. So 

18 there’ll be a lot of breaks today. If one group has 

19 settled and we’re still on a break, people can feel 

20 free to do whatever you’d like. That’s just the way 

21 things are at this stage of the game.

22 Again, we’re getting a lot of noise from 

23 people on the phones. Please mute your phones if 

24 you’re on the phone. Thank you.

25 And we’ll see how it goes. There is one 
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1 breakout right at the end of this hall here, people 

2 can also, I think, convene in the corner. There’s a 

3 not too elegant, but yet serviceable space back here 

4 behind me. Sorry we don’t have very good 

5 facilities, but they should be quite serviceable for 

6 people to go and caucus and talk among their groups.

7 I’ll try, for the benefit of people on the 

8 phone to at least roughly estimate how long we will 

9 be so if you’re requesting time to caucus, please 

10 give me a -- give us all sort of a rough time frame. 

11 I think that the advocates were saying about 15 

12 minutes, 20 minutes? Would that be enough?

13 MR. DeLASKI: I think that would be 

14 adequate.

15 MR. PARKER: Okay, why don’t we say people 

16 on the phone, it’s now about 9:30 -- yes, sorry, 

17 excuse me, John? Go ahead.

18 MR. CASKEY: John Caskey, NEMA. Are you 

19 saying that they’re going to go caucus now? Okay. 

20 How does that relate to at the end of yesterday, we 

21 were going to talk a little bit about data centers, 

22 and VJ was going to offer some information there. 

23 Are you going to wait until that group actually gets 

24 together and has some proposal to come back with?

25 MR. DeLASKI: We want to react to your --
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1 we’d like to react to your proposal. You made a 

2 proposal yesterday, so we want to react to that.

3 MR. PARKER: The new major items are 

4 proposals and data centers. I thought while they’re 

5 caucusing I could talk a little bit with Vijay and 

6 with Tom about the data center issue and we might 

7 make progress at the same time.

8 MR. CASKEY: Great. Thanks.

9 MR. PARKER: So let’s take a break and 

10 reconvene here at 9:45.

11 (Whereupon, at 9:31 a.m., the meeting was 

12 off the record to allow for a 30-minute caucus

13 period.)

14 MR. PARKER: Okay. Shall we get started? 

15 Sorry about the delay in reconvening, but we had 

16 some good conversations. Let’s --

17 MR. SMITH: Richard, if I say Hello, can 

18 you hear me?

19 MR. PARKER: Yes. We can hear you.

20 MR. SMITH: Okay. Thank you very much.

21 MR. PARKER: Okay. We’re back, everybody 

22 on the phone, we are reconvening. The advocates 

23 have caucused and are back at the table, and will 

24 share with us their revised proposal. Okay, Andrew, 

25 go ahead.
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1 Proposal

2 MR. DeLASKI: Thanks. And thanks. I 

3 think we had a really constructive conversation 

4 yesterday, thanks to NEMA for putting a proposal on 

5 the table and that was clearly explained and I think 

6 helped us to advance the discussions yesterday. So 

7 we really appreciate that. I think it helps us to -

8 - has been a very constructive step forward.

9 And we want to present a revised proposal. 

10 We weren’t able to focus on every aspect of your 

11 proposal in the time that we’ve had. We focused on 

12 the levels, primarily, but I want to comment on two 

13 of the things that Thomas explained yesterday that 

14 are -- before I get to the levels conversation. 

15 One is the issue of scaling. So, as I 

16 said yesterday, we are comfortable in principle with 

17 the scaling concepts that you outlined yesterday 

18 with respect to the transformers at the edges, and 

19 it was raised in the very first meeting, I think, 

20 and we’ve been comfortable all along with that. 

21 We’re comfortable in principle, we haven’t had time 

22 to analyze the specific numbers. We will. Our 

23 capacity to consider them I think will be, in part, 

24 dependent on the judgment of the consulting team, 

25 frankly, and doesn’t seem like the right factors --
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1 that’s something we can probably reach agreement on.

2 If we can get agreement on the main 

3 levels, we can get agreement on the scaling, I 

4 believe.

5 On timing, you suggested a three year lead 

6 time. We’re comfortable with that for you lead 

7 time, I think that’s the default in the law.

8 I appreciate your comments about learning, 

9 about what you can do today isn't what you can do in 

10 five years or ten years, and that you -- as you 

11 prepare for a standard you get smarter about how you 

12 can comply with that standard as you work with your 

13 designs and you work with your manufacturing, and 

14 that isn't achieved overnight. So I think -- three 

15 years I understand is what you expressed as the 

16 lower limit for what Schneider can do, and that 

17 smaller companies need more time, is what I heard 

18 you saying. And that -- three year we think is the 

19 default in the law, the question came up, would more 

20 time help. And I think the answer you came back 

21 was, not so sure it would actually help because it’s 

22 still the same problem, no matter when the timing 

23 is. So the timing -- I think I see a convergence on 

24 sort of the three year lead time and longer really 

25 isn’t that helpful is what I heard.
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1 So then to shift to the question of 

2 levels. We began, in our phone call a couple of 

3 weeks ago by proposing EL-5. Your current proposal 

4 was EL-2. We proposed EL-5 using the wound core 

5 exclusion scenario, because that is the maximum 

6 cost-effective level as shown in the wound core 

7 exclusion scenario. 

8 We are prepared to change our proposal to 

9 EL-4 for both design line seven and design line 

10 eight. We did not focus on design line six. We 

11 agree it has a small portion of the overall market. 

12 We haven’t focused on it.

13 Four -- what really brings us to four is 

14 reviewing the Navigant MIA prepared for DOE. When 

15 we look at five, the conclusion from the draft MIA 

16 is that five you’ve got to use high grade steel. 

17 Whereas at four, we see that the criteria of having 

18 multiple steel options is in the mix. So at four, 

19 just to quote from the manufacturer impact analysis, 

20 “CSL-4 offers manufacturers more flexibility than 

21 CSL-5, as mitered M3 and M4 options are also near 

22 minimum cost designs, depending on the price of HO

23 relative to those grain-oriented grades.”

24 So we see that at four, with M3 and M4 an 

25 option in the market along with the IV grades, that 
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1 that gives us the diversity of supply that would 

2 provide for the competition that would give options 

3 for steel makers and options for manufacturers and 

4 create sustained competition in the market.

5 In terms of construction techniques, we 

6 recognized this is either mitered course, that 

7 you’re not going to butt lap at four. We recognize 

8 that entails investments. We think manufacturers 

9 have multiple options for how to comply, either by 

10 making those investments in mitering equipment or in 

11 sourcing their cores across the range of 

12 manufacturer sizes. We also think that 

13 manufacturers have another option which is not 

14 explained in the manufacturing impact analysis, 

15 which is for the small -- the small KVA size 

16 transformers or the large volume transformers, which 

17 would be the shift to wound cores. The wound cores 

18 are a viable engineering option for high volume 

19 sales transformers, and that’s another option, in 

20 fact may be a less expensive capital investment than 

21 going to mitering. So we think there’s multiple 

22 options out there. This is not a single path for 

23 how one could comply at CSL -- I guess we’re calling 

24 them ELs, EL-4.

25 So you can make the investments, you can 
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1 buy the cuts, you’ve got a few different ways that 

2 you can comply.

3 So those are the main results. So we then 

4 turn back to the LCC analysis, with the wound core 

5 exclusion scenario, again, and we see that EL-4 for 

6 design line seven turns out that that’s the level 

7 that yields the greatest electrical cost savings of 

8 any option analyzed. It’s actually more cost9 effective than our previous proposal. 98 percent --

10 sorry, 97 percent of customers are estimated to be 

11 better off under that standard than without that 

12 standard. The mean payback is 5.7 years on a 

13 product that will last more than 30 years. So 

14 that’s really, from our perspective, a slam-dunk 

15 from a cost-effectiveness analysis point of view.

16 A DL-8, which is the larger transformer, 

17 the mean LCC savings are again -- it’s the minimum 

18 LCC point, it’s the level that yields the largest 

19 cost-effective -- largest mean electrical cost 

20 savings of any of the options, so it’s more cost21 effective than our previous proposal. 85 percent of 

22 customers are better off than without any standard 

23 at all. And the mean payback is 12.6 years, again, 

24 on a product that lasts more than 30 years. So 

25 again, a slam-dunk from our perspective. And I’m 
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1 just quoting from the wound core exclusion scenario.

2 So we see that as a standard level that 

3 has powerful arguments for it, one that has a lot of 

4 legs behind it, and one that would be, frankly, very 

5 supportable, and one that we think is a -- we 

6 understand -- doesn’t tell significant changes for 

7 parts of the industry, but the benefits are large, 

8 and that they would be easily cost-justified.

9 We also want to address the point that you 

10 raised in your comment yesterday about well, geez, 

11 you don’t get that much more for this relative to 

12 what you would have gotten if you just stuck with 

13 two. So Robin’s going to address that.

14 MR. ROY: Robin Roy, NRDC. We were 

15 mindful of this small incremental benefit going from 

16 the efficiency levels from two to three to four. We 

17 tried to figure out why that might be happening this 

18 way and what it really meant. And I think Katie’s 

19 e-mail last night was very helpful, at 10:20, that 

20 shows the number of transformers that are selected 

21 at each efficiency level. If you take a look at 

22 that, you see that in -- for design line seven, for 

23 example, in EL-1, something like 96 percent of the 

24 transformers are ones which meet an EL-4 level 

25 anyway. So that means the manufacturers would have 
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1 to be going through this adjustment to achieve these 

2 benefits. So it looks like what’s coming up in EL-1 

3 is largely what would be required to come up with 

4 EL-4. 

5 The same thing is in EL-2, we’re again 

6 picking most of the same transformers at a 98.8 

7 percent efficiency, same thing at EL-3. So for each 

8 of these efficiency levels, we’re relying on 

9 manufacturers making adjustment to an EL-4 level of 

10 performance in any case. That made us think, okay, 

11 so we wouldn’t really see that small increment 

12 necessarily, if the manufacturers weren’t able to 

13 make this adjustment, so there was already going to 

14 be that imposition -- that challenge.

15 The other question that came up is much 

16 more sort of a pricing question. If you were able 

17 to make a transformer that was minimally compliant 

18 and do that, even at the same cost or slightly 

19 higher, you’d probably price a premium product 

20 higher, just as market practice. It seems like it’s 

21 a reasonable way to operate. You see that in many 

22 industries, there’s a differentiation between 

23 different levels of that was minimally compliant 

24 and do that, even at the same cost or slightly 

25 higher, you’d probably price a premium product 
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1 higher, just as market practice. It seems like it’s 

2 a reasonable way to operate. You see that in many 

3 industries, there’s a differentiation between 

4 different levels of performance. Whatever the cost 

5 is, you try to price it in a way that differentiates 

6 higher performance from lower performance. So 

7 that’s why we didn’t feel that comfortable that the 

8 efficiency level two benefits that are shown here 

9 would actually be achieved, wouldn’t have those 

10 manufacturing challenges, and you’d probably see 

11 some smart pricing behavior. So that’s why we’re 

12 much more comfortable with DL-4.

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

14 Can you explain one more time what you’re saying 

15 about the premium idea and about selling high versus 

16 sort of lower efficiency?

17 MR. ROY: Sure. There is -- it’s possible 

18 to make a higher and a lower efficiency transformer 

19 as the LCC has gone about it, it shows in the lowest 

20 cost transformer, and that turned out to be a very 

21 high efficiency transformer. It turns out you can 

22 spend a little bit more in the way they’ve selected 

23 their transformers from that population of 

24 engineering designs that they have, spend more and 

25 make a less efficient transformer. And you wouldn’t 
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1 necessarily want to do that. But you’d like to have 

2 a differentiation in price between lower and higher 

3 performance. So one of these things that it’s nice 

4 to have a value added if you’re selling a premium 

5 product. 

6 We would expect that the manufacturers 

7 would like to have a range of products that are 

8 available and be able to differentiate their pricing 

9 across them. We also expect that manufacturers 

10 would find a way to optimize in a way that this 

11 engineering design space that’s being represented 

12 here doesn’t incorporate yet. We expect 

13 manufacturers to find a way to minimally comply that 

14 might actually be at the same cost or lower cost, 

15 which then is as suggested here. So we sort of see 

16 some sort of falling back towards lower cost at the 

17 minimum efficiency level that’s allowed in the EL.

18 MR. RIVEST: This is Mike Rivest. Just to 

19 bring in some -- some insight as to the construction 

20 of these cost curves. The -- for design line seven, 

21 the information that we had, and the corroboration 

22 with the OPS designs was very good at the baseline, 

23 and at EL-3. I think the data you’re seeing there 

24 shown as representing two, three, and four is 

25 representative of three. I think that the cost to 
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1 EL-2 is overstated and the cost to EL-4 is 

2 understated. Just consistent to what logic would 

3 dictate, and I think that your sales are going to be 

4 converging to the minimum requirement over time.

5 MR. DeLASKI: Mike, say again. The cost 

6 of EL-2 are overstated, and the cost of EL-4 are 

7 understated? Is that what you said?

8 MR. RIVEST: I believe so. Because 

9 they’re -- I know that they’re representative of EL10 3. And that applies to DL-7.

11 MR. DeLASKI: So the cost in the 

12 engineering?

13 MR. RIVEST: Yes.

14 MR. DeLASKI: Okay. 

15 MR. PARKER: What about for DL-8?

16 MR. RIVEST: DL-8, again, there was good 

17 corroboration at the baseline and at the NEMA level, 

18 which I believe is EL-2. Overall the cost 

19 efficiency curve of EL-8 is more consistent with 

20 expectation of an exponential.

21 MR. DeLASKI: And DL-7, as I understand 

22 it, is something on the order of three-quarters of 

23 the MVA sales, so DL-7 is going to drive the 

24 national impact analysis. It’s going to be the 

25 stronger driver --
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1 MR. RIVEST: Right.

2 MR. DeLASKI: -- on the NIA. We were also 

3 conscious that, you know, in this market, as we’ve 

4 talked about it over the last few meetings, that the 

5 first cost driver is a very powerful first cost 

6 driver. Your customers, the manufacturers’ 

7 customers are very focused on first cost, and we 

8 understand that. You made it clear again yesterday 

9 in describing the challenges in meeting the needs of 

10 a changing market, in a changing regulatory 

11 environment. So we thing that that first cost 

12 driver will drive manufacturers to find cost options 

13 that are truly the lowest cost option to comply at 

14 that minimally compliant level. 

15 And then we also understand that, you 

16 know, change is sticky. You know, that there’s a 

17 long term approach and your short term approach, and 

18 that the long term approach involves investments, 

19 significant investments -- you’re not going to go 

20 there immediately. So there’s the -- so even if it 

21 were to be cheaper, even if it were cheaper in the 

22 long term to be using your -- there’s some 

23 investments entailed there. It’s not going to 

24 happen immediately, or even necessarily ever, 

25 because of these factors driving you to sort of keep 
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1 things cheap -- low cost for your customers, given 

2 their market preference for low cost first products.

3 MR. LING: This is Peter Ling, 

4 Powersmiths. Can I speak for a couple seconds?

5 MR. PARKER: Yes, go ahead.

6 MR. LING: I’m not subject -- at 

7 Powersmiths, we’ve been exclusively in that high 

8 efficiency DL-7, DL-8 business since 2002 and we’ve 

9 shipped thousands of transformers in that category -

10 - two categories at EL-3 and EL-4. Now, what we’re 

11 finding, and we had to reoptimize our product, is 

12 that -- and it was brought up a bit yesterday a 

13 couple of times -- was that 35 percent, a very small 

14 percentage transformer loading that we’re actually 

15 measuring in the field -- and we’re doing a lot of 

16 retrofits in the field in performance contracts. 

17 The data is, as was discussed yesterday, 15 to 20 

18 percent is the true loading out there. The problem 

19 with driving up the efficiency at 35 percent load, 

20 it’s the wrong place to optimize. And so 

21 compromises that you’ll make in terms of -- as you 

22 know, in terms of building the lowest cost would be 

23 EL-4 at 35 percent, that’s a disadvantage 

24 performance in real world at 20 percent. 

25 Now it’s really the long optimization -- I 
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1 mean we had to go back because getting paid on 

2 dollars per watts saved, doesn’t matter what the 35 

3 percent load point is, it matters when you’re 

4 swapping out in the field, what the load is in the 

5 field, delivering the savings at that load. And 

6 again, and again, and again, the statistics are 

7 biased towards the 15 to 20 percent loading. And so 

8 we redesigned our products, optimized to that level, 

9 and it’s a very different optimization. And I think 

10 the time and investment and machinery and resources 

11 to optimize at 35 percent will actually not deliver 

12 the quads savings that you’re looking at and you 

13 will experience in the grid.

14 MR. DeLASKI: This is Andrew. I 

15 understand the point, and I appreciate it, but just 

16 to question back to the analysts, which is that I 

17 believe that the modeling and the NIA results we’re 

18 looking at do assume field loading of 15 to 20 

19 percent, is that correct? I see the LBL analysts 

20 nodding for those of you on the phone and can’t see 

21 them nodding.

22 MR. LING: Okay. The problem with that, 

23 though, is that, as Tom Patzner of Schneider said 

24 yesterday, the design focus and the focus on 

25 optimization will still be on meeting the legal 
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1 requirement which is a 35 percent load. When I go 

2 to my engineers and say, okay, if I’ve got to 

3 deliver the maximum watts savings, it’s a very 

4 different optimization process to optimize losses at 

5 20 percent, instead of optimize losses at 35 

6 percent. Completely different balance of materials 

7 happen as a function of that. 

8 MR. PARKER: This is --

9 MR. DeLASKI: Can I just comment?

10 MR. PARKER: Yes.

11 MR. DeLASKI: I’m sympathetic, and I 

12 understand, and I agree. I would like to have a 

13 test method that measures at a level of loading that 

14 is consistent with what consumers experience in the 

15 field. That is a shared objective that I would have 

16 with you. I don’t think we can address it right 

17 now. I would be very open to discussions on how we 

18 can address it and how we can get there.

19 MR. LING: A big challenge. I look 

20 forward to that because I think it would be a very 

21 productive process. I think it can be as simple as 

22 specifying another loss limit, either in absolute 

23 terms on a KVA basis or as a percentage of losses at 

24 the 35 percent loading losses. That way you’d not 

25 be optimizing to a single point, you’re optimizing 
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1 to do a point where losses are measured, calculated 

2 and all of that stuff. So there’s not an additional 

3 burden in terms of ...

4 MR. PARKER: Right. The problem, I think 

5 that Andrew alluded to, is that this group doesn’t 

6 really have jurisdiction to change or even recommend 

7 -- recommend in the same way that we can recommend a 

8 standard -- we don’t really have jurisdiction on 

9 test methods. That’s a different rule. My 

10 understanding was that also is that if there is 

11 consensus around the table, and in the industry, and 

12 with the experts that the test method as it stands 

13 now is flawed and ought to be changed, certainly it 

14 would be feasible for this group to recommend a 

15 change to the test method, and it should be possible 

16 to do something like a direct final rule or an 

17 expedited rulemaking as a separate process that 

18 would flow out of this process, that would address 

19 those -- that test process -- test method to make it 

20 more realistic. If it’s as clear as I’m hearing, 

21 that should be a relatively non-controversial and 

22 relatively easy fix. But I think it would be a win23 win --

24 MR. DeLASKI: No, no. Let’s not kid 

25 ourselves. It’s not going to be easy. It would not 
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1 be easy. It’s not -- this is not -- would not be 

2 easy at all. I don’t want to soft-sell this.

3 PARTICIPANT: It’s like standard levels, 

4 you rewrite everything.

5 MR. DeLASKI: We like to write test 

6 methods before we write standards, but we don’t 

7 always get that choice.

8 MR. PARKER: Okay. 

9 MR. DeLASKI: Okay. And the -- we don’t 

10 have that choice sitting here. So it’s just not a 

11 choice that we have. It doesn’t mean that we can’t, 

12 in good faith, after we develop the standard levels, 

13 work together to develop -- I mean it would have to 

14 come from NEMA. It would have to come out of the 

15 industry, because it’s an industry test method. So 

16 the industry would have to work to develop a change 

17 in test method and then we would -- the Department 

18 has mechanisms by which it can adjust standards 

19 after a standard is issued, with a test method 

20 change. But that is going to be a multi-year 

21 process, because again, it has to start with the 

22 industry to develop alternate -- to modify the test 

23 method. It’s a NEMA test method. 

24 So I’m looking at something that would be 

25 a commitment to work in good faith to address this, 
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1 and I haven’t even heard -- I think people would 

2 agree, but I’m not sure this is a universally held 

3 view, and that’s part of what the NEMA process, test 

4 method writing process is all about. John, I’m 

5 talking about your process, so I don’t want to go 

6 too far out on the limb here.

7 MR. PARKER: Well, I see this through the 

8 lens of administrative law, and as a matter of 

9 administrative law, if something is non10 controversial, which the predicate, there are 

11 reasonably simple procedures for making those kind 

12 of changes in rules. If it’s not straightforward, 

13 technically, and if it becomes controversial, well, 

14 that’s of course, a whole other issue. I think it’s 

15 clear, but it’s not something that this group can 

16 address around the table now.

17 MR. LING: But it’s not necessarily a 

18 change in the test method, it would just be setting 

19 a no load loss maximum, without changing the test 

20 method itself.

21 MR. PARKER: Can you --

22 MR. CYMBALSKY: It’s off the table.

23 MR. PARKER: Okay. It’s off the table.

24 MR. CYMBALSKY: Or table it.

25 MR. LING: The idea is just that --
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1 MR. PARKER: We got it.

2 MR. LING: -- optimizing and going through 

3 all those having it ... by 35 percent is the problem. 

4 How to deal with getting down to delivering real 

5 quads of savings which I think is what this goal is 

6 all about --

7 MR. PARKER: Right.

8 MR. LING: -- has to be achieved, 

9 obviously, in the simplest way possible.

10 MR. PARKER: Right. Good point. Okay. 

11 Yes, Rob, did you want to comment?

12 MR. GREESON: Rob Greeson, Federal 

13 Pacific. We came forth yesterday with level two --

14 let me just kind of share with you my -- kind of a 

15 viewpoint on that as far as technology goes with the 

16 cores. You guys just recommended EL-4, and I 

17 appreciate the fact that you guys acknowledge the 

18 fact that there was going to be a lot of investment, 

19 and I was going to mention that, and you took the 

20 words right out of my mouth. What’s nice about a 

21 little lower than that is the fact that you could 

22 design transformers that are much higher in 

23 efficiency than what we have now, but you have a 

24 diversity of manufacturers that I think we need to 

25 be considerate of. 
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1 You’ve got manufacturers like Federal 

2 Pacific, relatively low volume compared to say, a 

3 manufacturer such as Schneider, and perhaps even 

4 Cutler-Hammer. But if you pick the standard 

5 efficiency right, what you’ll end up with is the 

6 niche -- the small players and the niche players, 

7 you know, they have more options. They can -- you 

8 can still design a very high efficiency -- and 20 

9 percent lower losses, or 24 percent at EL-2 is 

10 pretty significant -- they can design the 

11 transformer in a number of ways. They can use butt 

12 lap technology with higher grades of steels. They 

13 can outsource, as you said. But depending on their 

14 market and the lead times available and the types of 

15 equipment that they have, they’ve got those options 

16 available to them.

17 Now, let’s move to the more -- the larger 

18 manufacturers who might have more investment 

19 capability. They’re going to begin to build these 

20 higher efficiency transformers. Perhaps initially 

21 they may even do the butt lap. And then they’re 

22 going to start working at the wound cores, and 

23 they’re going to start looking at their options with 

24 miter cores, and eventually, over time, there’ll be 

25 some capital investment, I think, to improve that, 
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1 because you’re talking about more volume of product 

2 and you can get your investment dollars back more 

3 quickly. Which kind of sets you up for the next 

4 step up in efficiency, because you start to slowly 

5 improve your capabilities over time.

6 And it seems to me that when you try to 

7 make the stair-step too much, you’re almost pushing 

8 -- you’re kind of pushing industry pretty hard, when 

9 a 25 -- 20 and 30 percent decrease in losses is 

10 really, really good, and at the same time you’re 

11 taking a moderate approach as far as pushing the 

12 industry with capital investment. Also, for 

13 compliance reasons, you’re getting an extra five 

14 percent anyway.

15 So, even at EL-2 with 25 percent, in 

16 reality, you’re getting an extra five percent 

17 savings that doesn’t show up because the compliance 

18 is really at NEMA premium 30. 

19 MR. DeLASKI: Rob, .. on that, just on 

20 that point, want to make sure -- we’re getting the 

21 extra percent in the base case too, aren’t we?

22 MR. GREESON: Yes.

23 MR. DeLASKI: So it’s not -- it’s not on 

24 top of the savings that we’re seeing in the model --

25 that compliance need is there in every scenario.
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1 MR. GREESON: It’s there, but it’s not in 

2 the analysis here. It’s assuming you’re right at 

3 the -- what we’re looking at here is not taking into 

4 consideration you’ve got five percent lower losses 

5 on average.

6 MR. DeLASKI: In the base case or in the 

7 standards case?

8 MR. GREESON: That’s right.

9 MR. DeLASKI: Okay. So I think the 

10 increment savings are the same -- we can take it 

11 off line, but I think --

12 MR. GREESON: Oh, I see what you’re 

13 saying, right. Okay. 

14 MR. DeLASKI: Right.

15 MR. GREESON: Nonetheless, I guess my 

16 point is that -- my way of thinking is that that 

17 gradual approach helps industry to adjust to it. 

18 The EL-4 is a much more abrupt change and it’s going 

19 to be difficult for industry to react and I think if 

20 we break together -- break out again and discuss 

21 this, it’ll be interesting what happens when we come 

22 back, I guess we’ll probably have some response to 

23 it. Thank you.

24 MR. SCHOEN: Jerry Schoen, AK Steel. I 

25 guess one of the questions I have, and it’s 
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1 following up on what Rob is saying. Right now, 

2 given that the economy is in not the best of 

3 condition, would these companies, these smaller 

4 manufacturers, a number of them we sell to, would 

5 they actually be able to get the capital to do this 

6 investment, or would this be something that if we 

7 did it in like two steps, three years, and then 

8 another step in three more years, would give them a 

9 chance to get through this rough patch right now and 

10 survive?

11 MR. TENDULKAR: This is Vijay Tendulkar, 

12 Onyx Power. What we are talking about is there are 

13 two kinds of the miter core units. One is a half 

14 miter, and another is a stapler miter. If you want 

15 to take the full advantage of the grain-oriented 

16 steel core steel and reduce the losses, you have to 

17 have a stapler miter, and that machine, as we said 

18 in the past, the cost of a million and a half 

19 dollars, and there are but two manufacturers in the 

20 world we can get it. 

21 If we are looking for a half-miter, 

22 smaller companies are using it today. Either they 

23 are doing -- have a facility in their own base or 

24 they are getting from other places. I have a 

25 picture here, I don’t know if everybody can see it. 
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1 This is called half-miter. But that doesn’t 

2 completely give the advantages of a miter core 

3 cutting. And that is the problem we are facing. 

4 Plus, the stapler miter, the full miter, is also --

5 takes lots more room to put in the factory, and also 

6 how much we are going to make off of that unit? 

7 Certain transformers you cannot use the miter cut 

8 designs at all. 

9 MR. DeLASKI: We’ve heard some -- I mean 

10 some different numbers about the cost of the 

11 machine. Vijay, you just put out $1.5 million 

12 dollars for the cost of a mitering machine. I heard 

13 $750,000 in some earlier meetings, so we’re kind of 

14 hearing numbers all over the place. I don’t know 

15 what the number is, but I assume it’s something that 

16 people can figure out.

17 MR. TENDULKAR: Maybe -- maybe the costs 

18 have gone down, but a couple of years ago we looked 

19 into that.

20 MR. DeLASKI: Yeah, I don’t know whether 

21 that’s --

22 MR. TENDULKAR: But the cost normally goes 

23 up, not goes down, but I don’t know.

24 MR. GREESON: This is Rob Greeson, Federal 

25 Pacific. I think maybe some of the -- you can get 
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1 bells and whistles on these things, the auto-stacker 

2 part of it adds some, and if you get the bare bones, 

3 the quote I got most recently was about three4 quarters of a million dollars. That was bare bones. 

5 It didn’t have some of the convenient auto-stacking 

6 capability --

7 MR. PARKER: That’s for a full miter?

8 MR. GREESON: Yes, step-lap miter. 

9 MR. DeLASKI: And the other option, I 

10 understand it’s not an option for low volume, but 

11 for higher volume products is to go to wound cores, 

12 and that’s an investment as well, I understand.

13 MR. GREESON: Rob Greeson, Federal 

14 Pacific. There are issues with trying to use a 

15 miter core cap with these smaller KVAs, but 

16 personally, the miter core technology is more cost17 beneficial in the larger ones, and -- well, let me 

18 back up a second, because there are different --

19 I’ve seen some other companies that have some miter 

20 core cutting technology that I think is probably 

21 faster. I’m not exactly sure how they do it, but 

22 I’ve seen one or two instances where it almost 

23 looked like the lamination was kind of stamped. But 

24 nonetheless, I know that’s probably an expensive 

25 investment too. 
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1 But it sort of depends -- a lot of 

2 manufacturers would probably choose to go wound on 

3 the smaller cores, but there might be some that 

4 might actually develop some of their own core 

5 cutting technology and come up with a -- sort of a 

6 miter core cutter that operates at a high enough 

7 speed so that you can get the proper yield to get 

8 your product out. But the miter core cutting 

9 machines we have, we could never cut the small cores 

10 and keep up with the production. There’s no way. 

11 We’d have to -- we just couldn’t do it. 

12 And if you try to -- I’m not an expert on 

13 the miter core cutters. Maybe there’s some out 

14 there that are a lot faster than ours with the 

15 smaller ones, but you’d have to find something like 

16 that. And if they’re anything like the ones we 

17 have, you wouldn’t be able to cut miters with -- in 

18 the smaller KVAs effectively and fast enough. So 

19 there’s just a lot of issues using -- there’s 

20 probably technology out there that I don’t know 

21 about, but it’s kind of complicated to say exactly 

22 for sure where they’d go. But certainly the miter 

23 cores are great and cost-effective, but you’ve got 

24 the time, the capacity issues to deal with as well.

25 MR. PARKER: Rob, a couple of clarifying 
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1 questions. When you said smaller KVAs, you’re 

2 talking 15 to 30?

3 MR. GREESON: I’m sorry, really, when I 

4 say -- for us with miter cores, for us right now, 

5 with our miter core cutting equipment, it’s like 300 

6 and above is where we like to use that technology, 

7 because the machines cut efficiently at that point. 

8 Try to do anything smaller, it just takes too long 

9 and the sorting of the steel and things of that 

10 nature. That’s why we support the EL-2, because you 

11 still have the butt lap options in that efficiency 

12 range, and yet, you also still get a 25 percent 

13 reduction in losses -- and I think that’s really 

14 good. And that kind of goes back to what I said 

15 earlier that a more gradual step approach to 

16 industry to kind of adjust to the technology in a 

17 more gradual way.

18 MR. DeLASKI: The numbers I’ve heard for 

19 the machinery investment for wound cores, I’ve heard 

20 numbers on the order of $150,000. 

21 MR. PARKER: That’s different from what I 

22 have.

23 MR. BROWN: Chris Brown with Cogent Power. 

24 We’re a core maker. So all this stuff is pretty 

25 familiar to us. We make large cores, stock cores, 
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1 wound cores, we make them all. We buy all the 

2 equipment all day long, and we’ve got various 

3 investments coming in at the moment. 

4 Costs. Wound core, put a wound core, a 

5 simple wound core, you’re probably looking at 

6 $250,000. That said, wound cores, to perform 

7 effectively and to make the best use of the 

8 material, the wound cores require annealing as well, 

9 and so you’re looking at added annealing costs for 

10 wound cores.

11 MR. PARKER: How much?

12 MR. BROWN: For what -- let’s just say 

13 we’re trying to put a simple operation in, you could 

14 probably be in the wound core business for something 

15 to the tune of a half a million to $750,000, and 

16 then you’re appropriately making wound cores.

17 Stack cores. Stack cores, to do what Rob 

18 was saying, there is a certain effectiveness of 

19 stack cores. It just doesn’t really make a whole 

20 lot of economic sense to put narrow bits of material 

21 through stack core lines, and so when you get down 

22 into very small -- you get miter mites (ph) so when 

23 you get down into very small transformer cores, I’d 

24 struggle with the actual KVA ratings, but Rob, you 

25 can jump in if you’d like, but when you get down 
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1 into smaller cores and putting the very narrow strip 

2 steel through, you don’t want to be doing it. It 

3 just doesn’t make any economical sense and 

4 therefore, you don’t really see that kind of 

5 technology, certainly in the North American market, 

6 because one, you’ve got a butt lap design, and two, 

7 you’ve got a wound core option. If you -- you can 

8 see some of this technology vis-à-vis narrow, 

9 mitered cores, but you’ll typically see it in other 

10 markets like Europe, where they’re not akin to using 

11 wound cores in any way, shape, or form because it’s 

12 -- the wound core is really an American invention 

13 and it’s really pretty much stuck, for large part, 

14 in North America. It’s in other markets around the 

15 world, but it’s certainly not in Europe. So you 

16 have a tendency, if you want to make a small dry 

17 type KVA, if you want to make an efficiency, there 

18 is some of that technology over there.

19 So I hope that helps to -- some of the --

20 MR. PARKER: So, Chris, what is your 

21 threshold of small where you face these 

22 difficulties?

23 MR. BROWN: Well, we’ve got -- we opt for 

24 a good, medium-sized step-lapped fully capable core25 cutting line at our facility, and we’ve got two more 
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1 coming in in the next few months, and this market 

2 does not demand, at this moment in time, cores that 

3 -- again, help me, I mean strip widths down in below 

4 three, four inches start to make a real nonsense out 

5 of cutting a miter core. What KVA rating that would 

6 be --

7 MR. GREESON: One twelve and a half KVA 

8 would be either four and a half or five inch. One9 fifty would be probably a five or a five and a half. 

10 And 75s, you’re going to be four, four and a half.

11 MR. BROWN: These lines are -- they’re 

12 highly sophisticated lines and it’s not just the 

13 strip width, but it’s also the length of the -- it’s 

14 the height of the core. And because the shearing 

15 lines need space from one distance to another, if 

16 the core is too short, you just simply can’t get it 

17 done. And so our sort of take on it is that we stay 

18 up in strip widths that are probably wider than four 

19 inches, which would be a KVA rating of rough --

20 MR. GREESON: Seventy-five.

21 MR. BROWN: Yeah.

22 MR. GREESON: If you stay above four 

23 inches, at four inches you’re easily in the 75 KVA 

24 range.

25 MR. BROWN: So then and below that our 
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1 solution to market is to provide a wound core if the 

2 customer is looking for an efficient product, and 

3 you can certainly take that down. But again, you 

4 get smaller, there’s a certain point where you just 

5 flat, butt lap steel is the most effective way to go 

6 and it’s going to be for a long time.

7 MR. PARKER: Do we have data on the volume 

8 of shipments at the various KVAs? Do we know what 

9 the MVA shipment volumes would be for, say, 75 KVA 

10 and below?

11 MR. PATZNER: Tom Patzner from Schneider 

12 Electric. The KVA data is in the portal in one of 

13 the 24 chapters of documents that -- I think it’s 

14 Chapter five, but it is broken down by KVA. If we 

15 did a breakout, I don’t have an index -- oh, wait, I 

16 have the documents on my hard drive. I’ll try to 

17 find it, but it is done by KVA size.

18 Thomas Patzner, Schneider Electric. With 

19 regards to this, I don’t believe the 15 KVAs and 30 

20 KVAs will be switched at all. I made this point 

21 multiple times. The industry is going to buy 

22 resident encapsulated. So we can discuss what we 

23 need to do on the 15s and 30s. The industry today 

24 is readily available today of resident encapsulated. 

25 The large number of the small manufacturers, for the 
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1 points that were brought up, already only build them 

2 as resident encapsulated. 

3 So that being the case, I guess from my 

4 perspective, the industry, on those two KVA sizes, 

5 will definitely switch and they’ll be buying wall6 mounted devices instead of the floor-mounted 

7 devices.

8 MR. DeLASKI: Thomas, at what point does 

9 that happen? Does it happen at EL-1? Does it 

10 happen at EL-2? What’s the trigger that puts you --

11 maybe they’re already happening today, I guess is 

12 the question.

13 MR. PATZNER: Thomas Patzner, Schneider 

14 Electric. I’m not seeing the shift today. With the 

15 NEMA tracking data, we have requested the breakouts 

16 so that it will be easily tracked as total market, 

17 so we’ll be able to track it moving forward. That’s 

18 going to start next year. We could -- NEMA probably 

19 could break it out today, compared to 2005, 2006, 

20 but it would take some work with their analysis. 

21 But the way we -- the NEMA membership voted on how 

22 to track the market, and we just have set it up, so 

23 we’ll be able to track that movement forward. So 

24 that information will be available through NEMA to 

25 DOE and how they’ve done it in the past.
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1 MR. DeLASKI: Right. We’ve heard you on 

2 this concern before, and we share it, and we’ve been 

3 looking a little bit into sort of what we think the 

4 options are from a legal perspective on how this 

5 problem could potentially be mitigated. Tim, you 

6 want to comment now, or something we can look at and 

7 maybe comment on later, but we’ve been looking into 

8 it.

9 MR. BALLO: Tim Ballo, Earth Justice. One 

10 of the things we’re thinking about -- well, 

11 obviously, this is a regulatory definition for 

12 sealed and non-ventilating transformers and so it 

13 can be changed. Is there sort of a threshold now 

14 where they’re not made -- the sealed units are not 

15 made above 30 KVA where we can sort of keep them 

16 from at least spreading into the 30 KVA ratings?

17 MR. PATZNER: Thomas Patzner, Schneider 

18 Electric. If you look at the EL-listed product, 

19 it’s UL listed through 75 KVA in the marketplace. 

20 However, the 45s and the 75s, because of their, as 

21 we stated many times, the price sensitivity of this 

22 market, become more expensive to build as resident 

23 encapsulated. So only customers that need the 

24 device completely protected from the environment are 

25 buying them today. And those two markets would be 
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1 Petrochem and Wastewater. So there’s basically two 

2 marketplaces today that are buying them today, but 

3 they are UL listed through 75 KVA.

4 Based on the target sub-prices we’re 

5 seeing, which you could just -- you can see the 

6 graph, because it’s price sensitive, so you can see 

7 when it crosses -- when each KVA’s potential target 

8 price crosses where you can buy it as an 

9 encapsulated is where it’s going to switch, to 

10 answer that question, Andrew.

11 MR. DeLASKI: You can see the price, we 

12 can’t. I totally agree, this is an issue that we 

13 need to continue to wrestle with, at these small --

14 at the smallest KVAs, and thanks for finding that 

15 data because I’ve been looking or the data on the 

16 KVA by unit and I haven’t been able to lay my hands 

17 on it yet, so hopefully you can pull it up at the 

18 break. I had a follow up question --

19 MR. PARKER: Tom, if it’s on your hard 

20 drive, if you can, maybe at the next break, if you 

21 could send it around, I think that would be actually 

22 very helpful for us today. I appreciate that.

23 MR. GREESON: Rob Greeson, Federal 

24 Pacific. At the present energy efficient levels, on 

25 the 15 and the 30, would it make sense to just leave 
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1 those alone for now on the basis that if they did --

2 in other words, if they switched over to the 

3 encapsulated, you’re going to lose those savings, 

4 but you’re already getting pretty good savings now 

5 compared to -- well, especially compared to where 

6 they were in 2006. Or at least radically -- I think 

7 we had suggested yesterday we kind of adjusted the 

8 curve some, but maybe we adjust it a bit more to 

9 mitigate the possibility of that happening, since 

10 you still get the savings off those two KVAs. Maybe 

11 we sort of relax it even more than we discussed, to 

12 make sure that doesn’t happen, but that’s just an 

13 idea. Thanks.

14 MR. DeLASKI: Just to respond. I think 

15 it’s certainly an idea worth exploring. And again, 

16 we come back to what we care about the energy 

17 savings, so come back to that, so it’s an idea worth 

18 exploring. I appreciate that we got at it --

19 perhaps we got at it partially with the scaling 

20 factors that you all shared, I just don’t know.

21 I had a follow-up question for Chris, 

22 which is, I’m still -- this has all been fantastic 

23 learning. I’m learning a lot, continuing about the 

24 industry’s structure. So as a core supplier, can 

25 you -- is it Chris, do I have the right --
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1 MR. BROWN: Yes, Chris.

2 MR. DeLASKI: Okay. The market that you 

3 supply, would you characterize it as primarily 

4 smaller manufacturers, primarily larger 

5 manufacturers -- because that’s one of the options. 

6 One of the options for folks is to make the 

7 investment, the other option is to buy from a 

8 company like yours. And I assume there’s more. 

9 You’re sitting here and I don’t know whether there’s 

10 a dozen or two dozen, I’m learning about market 

11 structure here and what their options are for 

12 companies.

13 MR. BROWN: Okay. I mean, roughly, we 

14 have a pretty good sense of the overall transformer 

15 market in North America, and -- because we’re steel 

16 guys. We count in tons and pounds and things like 

17 that. And we supply from our facility, about ten 

18 percent of the market on the grain-oriented business 

19 -- and that’s the market between say, Canada, US and 

20 Mexico. And if there is -- every company in the 

21 transformer industry sits inside our order book. 

22 All the large -- most of the large, multinationals, 

23 a good number of the national customers --

24 MR. DeLASKI: Big? Small?

25 MR. BROWN: Big, small, medium, yep, we’re 
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1 supplying all of them to some degree. In some cases 

2 holistic, full 100 percent supply, and some 

3 partials, some augmenting, the whole market.

4 MR. DeLASKI: And I see Scott nodding his 

5 head indicating a similar -- do you all have a trade 

6 association of companies that do what you guys do? 

7 No. Okay. 

8 MR. PARKER: Can I just ask one clarifying 

9 question and if this is in any way proprietary and 

10 people don’t feel comfortable sharing it, just let 

11 me know. But is there a sense generally in the 

12 transformer manufacturing business, of the sort of 

13 breakdown of markup between the manufacturing of the 

14 core and making the rest of the transformer? Is it 

15 possible to generalize at all about how much of your 

16 overall markup you lose if you decide to outsource 

17 your core as opposed to making it in house? I just 

18 don’t get a sense -- in other words, how much of the 

19 value added -- how much additional value added there 

20 is once you get the core in proportion to the value 

21 added of making the core itself, I guess is what I’m 

22 trying to get at? Wes, did you have a comment?

23 MR. PATTERSON: Wes Patterson, ABB. 

24 General numbers, at least in the medium voltage 

25 space, the material cost as we’ve always said, as 
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1 arbitrary numbers is 50 percent of selling price. 

2 And of that 50 percent, more than 20 percent of it 

3 is sitting in the core steel. And this is 

4 purchasing the steel, then you have to put your 

5 labor and stuff in it. 

6 I’d like to come back with a comment from 

7 Chris. Chris, clarifying comment. When you 

8 reported ten percent, this included power 

9 transformers?

10 MR. BROWN: Yes.

11 MR. PATTERSON: Distribution?

12 MR. BROWN: Right.

13 MR. PATTERSON: Dry type, the whole 

14 market, right?

15 MR. BROWN: Right.

16 MR. PATTERSON: Another clarifying 

17 statement. Chris is a supplier to ABB, right?

18 MR. BROWN: Yeah.

19 MR. PATTERSON: He doesn’t just supply 

20 finished cores. He supplies cut steel, and then the 

21 steel is then fabricated back in the factory back 

22 into the core, isn't that correct?

23 MR. BROWN: Yeah.

24 MR. PATTERSON: So -- and just so -- it’s 

25 not the concept of a wound core going into a 
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1 factory, complete ready to use. It’s in various 

2 stages along that production cycle.

3 MR. BROWN: Right

4 MR. DeLASKI: And I think that’s -- thank 

5 you for that clarification. I think that’s part of 

6 the challenge, Richard, in answering the question 

7 you were posing, which is that businesses have a 

8 variety of choices and you can’t simply break it 

9 down into this sort of simple, you buy the core or 

10 you don’t. There’s a range of choices that they 

11 have and that that is going to depend on their 

12 business circumstances. I also think that the thing 

13 that’s difficult for us to, as a non-manufacturer, 

14 to understand is that the manufacturers are often in 

15 -- they each have a different business, right. ABB 

16 is quite different than any of the other companies. 

17 And each -- not even in the way we’re talking about 

18 today, and to -- a particular transformer line may 

19 or may not be a big part of their business. Their 

20 overall business. So I think it’s difficult for us 

21 to answer your question in a sort of cut and dried 

22 manner.

23 MR. PATTERSON: But Andrew, it is the 

24 largest single component of our production costs. 

25 There is no other component in our entire production 
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1 cycle that is the magnitude of core.

2 MR. DeLASKI: To your business. I got it.

3 MR. PATTERSON: In all transformers. It’s 

4 the nature of the transformer.

5 MR. DeLASKI: Right, and then some of the 

6 small businesses, I think that we’re talking about, 

7 are, you know, suppliers of electrical -- we talked 

8 about the power, we talk about -- where is Vijay --

9 we’re going to talk about -- later today we’re going 

10 to talk about his business, which I think is a very 

11 different business -- it’s a very different business 

12 than ABB in a lot of different ways. We have to be 

13 able to sort of think about those separately.

14 MR. PARKER: Yes, Wes, I just wanted to 

15 follow up on this. What I hear you saying is that 

16 when you’re making the core, the vast majority of 

17 the cost is the material.

18 MR. PATTERSON: This is correct.

19 MR. PARKER: And the additional mark-up 

20 from shaping that material into the actual core is a 

21 relatively small additional mark-up, on the order of 

22 ten to 20 percent, is that --

23 MR. PATTERSON: Relative to the cost of 

24 the material, correct.

25 MR. PARKER: Right. So if the company 
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1 were to outsource the core, on the one hand, they 

2 would be making a major purchase, but as I 

3 understand it what you’re saying is a lot of that 

4 cost they would have incurred anyway for just buying 

5 the steel. What they would be foregoing in terms of 

6 markup would -- that’s what I’m trying to get at. 

7 What would they be foregoing in terms of profit and 

8 markup if they were outsourcing the cores.

9 MR. PATTERSON: I don’t understand your 

10 question from a manufacturing perspective. When we 

11 look at any part of our supply chain, any part, we 

12 look at it both from an insourcing and an 

13 oursourcing perspective. So we have a price that 

14 we’re trying to get to the customer, right. And we 

15 have internal costs. And we have to make a margin 

16 on our cost, be those internal costs or purchase 

17 costs from Cogent. Okay. So what we’re trying to 

18 do is minimize our cost structure so we can minimize 

19 our price to the market and be more competitive.

20 So having a markup change really is not 

21 the driver. What the driver is is what kind of 

22 margin can I make on my cost structure? I have an 

23 investment that I’m making and I want to get a 

24 return on my investment, and I have multiple ways of 

25 making the investment. One is I can build up the 
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1 infrastructure in house to make the investment, or I 

2 can go to Cogent and buy it. So it’s not a matter 

3 of how many profit dollars do I lose because I build 

4 in house or buy, that’s not the issue.

5 MR. PARKER: I didn’t frame the question 

6 well. Rob, go ahead.

7 MR. GREESON: Rob Greeson, Federal 

8 Pacific. As far as percentages, if you look at a 

9 percentage of the core cost of material as our 

10 efficiency levels increase, for 600 volt it becomes 

11 a higher percentage of the material cost, I 

12 understand, looking at the designs, I’ve got a 

13 variety of different efficiencies, and different 

14 steels and different types of cores. Not looking at 

15 the labor it takes to construct the core, just 

16 looking at the material, it’s between 60 and 70 

17 percent -- it’s quite a bit larger for the ... product 

18 because on the medium voltage side you’ve got the 

19 costly installation. Cores are bigger too, but on 

20 the 600 volt side, you’re going to see the core 

21 being an even greater component of the overall cost. 

22 So it’s true in both cases, but even more so with 

23 the 600 volt.

24 MR. PATTERSON: And I agree with Rob, as I 

25 stated, my 20 percent was coming from medium 
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1 voltage, which has lots of insulation and other 

2 stuff around it. When I get into a 600 volt class 

3 product, essentially you just have a -- the basic 

4 coil itself, and the copper, the steel I mean, the 

5 core steel. The coil and the steel. And the steel 

6 that is becoming a much bigger proportion of the 

7 total material cost.

8 MR. PARKER: I was just trying to see if 

9 there’s any way to get at sort of -- in the 

10 hypothetical world, where certain manufacturers 

11 decide that it’s not worth investing in capital 

12 equipment to miter and so forth, and they decide to 

13 outsource their cores instead of producing them in 

14 house, I’m just trying to get a sense of whether the 

15 impact on that profitability would be large or 

16 small. Because the cost of the steel is the cost to 

17 them if they make it in house, so what really 

18 matters is the value added after that. I was just 

19 trying to get a sense --

20 MR. MILLURE: Dave Millure, Metglas. I 

21 think the cost of the steel would probably be less 

22 because these guys buy a lot of steel, and we’ve 

23 heard before that the smaller guys pay more for 

24 steel So these guys will have a lower cost base to 

25 start.
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1 MR. PARKER: I’m just trying to see if 

2 there’s any way that we could sort of get a handle 

3 on the loss of profitability for these companies as 

4 opposed to, you know, for when they decide to 

5 outsource. But let me not belabor that point.

6 MR. DeLASKI: One of the things that I’m 

7 struck by in this conversation, I come back to the 

8 point that I think Jerry Schoen made, is that there 

9 is, you know, we acknowledge that there are 

10 investments that are needed, there are changes that 

11 are needed to comply with new standards. And making 

12 those decisions and the choices that manufacturers 

13 face in a way to help them to maintain their 

14 business and to grow their business and to figure 

15 out how you work. And regulatory change means 

16 change. I mean we’re not soft-pedaling that there’s 

17 change involved in complying with new standards. 

18 But one of the ways to mitigate that is to address 

19 the issue of timing, and again, I come back to what 

20 I’m hearing here is that is there -- does timing 

21 help to address the issue of giving manufacturers 

22 what they need to -- giving them more flexibility to 

23 meet the compliance date while making the best 

24 choices for their business, given this range of 

25 choices.
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1 That point to a potential to a two-step 

2 standard? We discussed a couple of times. Jerry 

3 referenced today, or looking at compliance dates as 

4 a way to give people more flexibility.

5 MR. SCHOEN: Jerry Schoen, AK Steel. We 

6 had a discussion -- somebody mentioned it, and I’m 

7 not sure if it was Thomas or if it was Robert, or 

8 maybe it was Russ -- about the time it took from 

9 when TP-1 was put into effect in 2007. The 

10 manufacturers first kind of struggled with it then

11 they got astride, it took some couple of years --

12 whichever one of you made that comment, could you 

13 repeat it, because I think it bears on this.

14 MR. PATZNER: Thomas Patzner, Schneider 

15 Electric. The transition -- we are just finally at 

16 the point of having our most optimal designs. And 

17 some of that was due to the fact that the federal 

18 registry 429 was not finalized until this year. So 

19 some of the things that came out in that registry 

20 caused us to make some changes to how we were 

21 building the product because we now need to be more 

22 strict on what we’re putting out, because the rules 

23 are now 100 defined where they were -- hate to say 

24 this word, but they were lax before that, because 

25 they weren’t defined. So you met the efficiencies, 
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1 you didn’t have to register your product and so 

2 forth.

3 The date that -- from 2007 -- we’ll remove 

4 2008 because of the volatility of the steel market -

5 - so we really didn’t start reducing our cost until 

6 2009. Also what occurred is the market dropped out 

7 below us, so we also had the ability that there was 

8 now price pressure on us to actually do that as 

9 well. So 2009, 2010, 2011 and I always look at it 

10 based on tracking the actual purchase price by the 

11 end user. The purchase price for the end user 

12 spiked in January 2007. It went up again in 2008, 

13 mostly because of the ability to obtain steel, it 

14 just was a natural aggression to go up. It came 

15 down a little bit in 2009. It did not really start 

16 coming down until 2010 and 11. 

17 So to answer your question, the market 

18 really didn’t see us getting to the cost competitive 

19 designs until four years after the law went into 

20 effect.

21 MR. DeLASKI: An observation, and frankly, 

22 the one that we see time and time again was the 

23 standards, right, whatever the product is, which is 

24 it takes time for manufacturers to truly optimize. 

25 You see a cost -- typically what happens is the cost 
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1 increases that are predicted materialize initially, 

2 and then over time they erode.

3 MR. PARKER: Yeah. I think we need to --

4 let’s take a break and think about the proposal that 

5 we’ve heard and that we’ve had a discussion about, 

6 and reconvene in about 15 or 20 minutes. Okay. 

7 Thanks.

8 (Whereupon, at 11:04 a.m., the meeting was 

9 off the record for a 44-minute period.)

10 MR. PARKER: Okay. If we can reconvene. 

11 First, I apologize, that was sort of a Bill Clinton 

12 15 minutes, but we -- we had a number of very good 

13 conversations on the side during the break, and I 

14 think what would be the most prudent way forward at 

15 this point, since I understand that NEMA and perhaps 

16 others need to caucus with their members more 

17 extensively before taking any firm positions, I 

18 think it would -- my sense is that there’s agreement 

19 that it would not necessarily be beneficial to try 

20 to go forward with proposing and counter-proposing 

21 standard levels at this point today. 

22 But that it would be useful to gather some 

23 more information that would help us make more 

24 enlightened decisions. And in particular, some 

25 information that will need to be gathered in any 
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1 case as part of the rulemaking, whether or not we 

2 come to an agreement, which is the impact on small 

3 manufacturers. That’s a part of the agency’s 

4 standard analysis and I think our manufacturing 

5 impact analysis has gotten a very good start to that 

6 but I think there’s a sense all around that we can 

7 refine that analysis by going back to the relative 

8 handful of small manufacturers who are operating in 

9 this space to pose a combination of purely factual 

10 questions. What is their volume of sales of covered 

11 products compared to exempt products on a company 

12 basis? As well as some not so obvious questions, 

13 and perhaps somewhat speculative questions that go 

14 to the question of what would be the impact on their 

15 company’s profitability from moving to one level or 

16 another level. 

17 I pose these as categories of questions. 

18 I’m certainly not expert at forming these questions, 

19 and I think that is something that Mike Rivest and 

20 Navigant and Rob Carmichael and his team who are 

21 very adept at this kind of analysis can refine. I 

22 did suggest that since, due to the shortness of time

23 and the importance of the issue that they take a 

24 stab at drafting up a set of questions that they 

25 think would be useful in informing this process, and 
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1 circulate it to a working group of this plenary, 

2 just for their general review just to make sure that 

3 everybody’s comfortable that these are the sorts of 

4 questions that would be most helpful to us before 

5 they then pass those along to the manufacturers.

6 My guess is that these questions would be 

7 asked in phone calls. It’s not going to be some 

8 sort of formal questionnaire that’s going to go out 

9 backed by subpoena power or anything like that. So 

10 that would be the approach -- we’ll try to have that 

11 process done next week, with the goal of being able 

12 to report back something to the group the week after 

13 that. Is that reasonable? 

14 And then I think what we should do is set 

15 up a conference call -- I’m not -- I’m open to 

16 setting up a time now if people feel that that would 

17 be beneficial. We have conference call for the 

medium voltage on December 14th 18 at 11, so from our 

19 perspective, that’s the only time that is not 

20 available, but I’m open to suggestions for -- for a 

21 time after that. Does anybody want to propose a 

22 time? How about 11 on the -- I guess my own 

23 preference would be to give this time since we’ve 

24 had such a track record of last minute -- I think 

25 Navigant has been put through its paces by our group 
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1 pretty heavily. I’d rather err on the side of 

2 giving them plenty of time, and perhaps -- at the 

3 same time we get into the Christmas season so it’s 

4 complicated situation, but you want to make a 

5 proposal?

6 MR. DeLASKI: Well, I still have 

constraints like I did yesterday, on the 15th 7 and 

16th 8 , I’m not available those two days because of 

all-day meetings or hearings. And so the 14th

11 MR. PARKER: What about the following 

12 week, does that --

9 , I’m 

10 available in the afternoon, after --

13 PARTICIPANT: How about Tuesday?

14 MR. PARKER: What’s that? I’m free on the 

20th

16 PARTICIPANT: That’s good.

15 .

17 MR. PARKER: Is everybody doing egg nog? 

How about December 20th

19 PARTICIPANT: Let’s do it.

18 at 11 a.m.?

20 MR. FERNSTROM: That would be 8 a.m. 

21 Pacific, right?

22 MR. PARKER: It’s eleven minus three is 

23 eight.

24 MR. DeLASKI: Does that work for you, or 

25 do you want to go to one p.m.?
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1 MR. PARKER: Is that okay with you --

2 MR. DeLASKI: West-coasters?

3 MR. FERNSTROM: It doesn’t matter to me, I 

4 just wanted to clarify what time it was.

5 MR. PARKER: What time zone. 

6 PARTICIPANT: How long would it go, an 

7 hour?

8 MR. DeLASKI: Allow two.

9 MR. PARKER: I would allow two hours.

10 MR. FERNSTROM: So that’s great, 11 

11 eastern?

12 MR. PARKER: Yes. And if we could aim to 

13 have --

14 PARTICIPANT: Eleven to one?

15 MR. PARKER: Eleven to one eastern.

16 MR. FERNSTROM: Okay. Eleven to one 

17 eastern.

18 MR. PARKER: Okay. So the last item of 

19 business today - that gives us -- puts us ahead of 

20 schedule in terms of getting out of here for the 

21 afternoon on a beautiful day. What we do need to do 

22 in our last item is to discuss the issue of data 

23 centers. I don’t -- we have a working group formed 

24 on that and Vijay has kindly agreed to head that 

25 group and I know Tom Patzner’s been working on that. 
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1 I understand they don’t have a firm proposal at this 

2 point, but I think it would be helpful to all of us 

3 to hear what Vijay and Tom have to say. Can we do 

4 this in about 20 to 30 minutes? Is that enough time 

5 for your proposal?

6 MR. TENDULKAR: I think so.

7 MR. PARKER: Okay. Let’s aim for that, 

8 and then we’ll have a short discussion, mostly for 

9 clarifying questions at that point, and then we’ll 

10 adjourn for lunch. Go ahead Vijay.

11 Data Center Transformers: 

12 Preliminary Analysis from Working Group

13 MR. TENDULKAR: This is Vijay Tendulkar 

14 from Onyx Power. We are talking about the data 

15 center transformers. And one of the things we have 

16 is the data center transformers have very special 

17 requirements. Currently data center transformers 

18 are included in the DOE’s definition of the 

19 distribution transformers and therefore they had to 

20 meet the current efficiency requirements. The data 

21 center transformers are normally use to use to 

22 supply the power to the servers, computers, 

23 printers, in the big data center buildings. Power 

24 normally comes from the UPSs and the utilities and 

25 maybe another UPSs, and power is transferred from 
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1 the once source to another source in a very rapid 

2 succession within less than a cycle. That is a lot 

3 of inrush current on a transformer and it can trip 

4 the breakers and drop the data center down. 

5 Therefore, a lot of these data center 

6 transformers are designed to have minimum inrush 

7 current in the normal specifications of about 300 to 

8 400 hundred percent of the inrush current. That 

9 puts them in a very difficult position to be 

10 designed with the grain-oriented steel, with the 

11 wound cores or even with the miter core 

12 constructions.

13 We normally use butt lap and the non14 oriented steel, because the butt lap -- the non15 oriented steel and the oriented steel has a slightly 

16 different characteristics as far as the remaining 

17 flux density in the core. What I mean by that, when 

18 you ... the transformer and you switch the transformer 

19 off, there is a flux density remaining in the core, 

20 and that flux density has quite a bit of effect on 

21 what the inrush current piece is going to be. The 

22 higher the flux density, you will have a higher 

23 inrush current.

24 The oriented core M6 and above have a VH 

25 curve is a very slender and almost ... tangular (ph) 
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1 configuration. There is on the non-oriented core 

2 the VH curve is fatter, that is that it has like 

3 more losses, but it has got the curve on the both 

4 sides of -- positive and negative side -- and the 

5 minimum flux density is lower. And that’s one of 

6 the reasons why we tried to use non-oriented cores 

7 to design this transformer so the minimum flux 

8 density is lower and the inrush currents are lower. 

9 Of course we use at a very low flux density, also in 

10 the cores.

11 Using the very low flux density in the 

12 core also increases the windings size, core size, 

13 and the transformer size. These data center 

14 transformers are also have to supply the loads with 

15 a lot of harmonics. And the data center 

16 transformers normally form a buffer between the high 

17 harmonic loads and the UPSs and the utility, and do 

18 not allow all the harmonics to pass to the utility. 

19 The harmonics is the bad news in any kind 

20 of installations. These harmonics are -- either 

21 flow in the secondary transformer, not necessarily 

22 in the primary, or if they are in the primary, they 

23 are reduced. Because of that, the data center 

24 transformers need to have a high K factor 

25 characteristics. Normally the K factors on the 300 
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1 KVA and below are about 20, and about 300 KVA is 

2 about 13, and then 750 and 1000 KVA, it is lower 

3 than that. This is at 150 degrees rise. If you 

4 have a rise lower than 150 degrees, the K factor 

5 reduces.

6 What does exactly that mean? If you take 

7 a 750 KVA transformer for example, and you load it 

8 at a load with a K-13 load, the winding losses at 

9 the K-1 to the winding losses at the K-13 load, they 

10 are 300 time higher than the normal losses. That 

11 means we have to cool this transformer quite a bit, 

12 and that makes a lot of differences in the core 

13 construction also.

14 As we were talking a little this morning, 

15 what would be the width of the core for the smaller 

16 transformers and we were talking about three inches, 

17 four inches, but in the data center transformers we 

18 had to go much wider width than that from the same 

19 KVA because it increases the cooling area in the 

20 ducts, and because of that, the core weight goes up, 

21 also the core losses go up. And because of that we 

22 have a difficulty meeting even today the TP-1 

23 efficiency requirements. 

24 If we go to the higher efficiency 

25 requirements than TP-1, we may not be able to 
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1 provide the transformers to the industry with the 

2 performance requirement they are asking for.

3 The data center transformers are normally 

4 put in the enclosure called PDU, and I’ve got some 

5 pictures and I’ve got some prints that are here, and 

6 there’s some pictures on the -- Mr. Parker has on 

7 his e-mail -- we can look at that if we want to. 

8 But that will tell us how these transformers are 

9 constructed. Normally, there is one transformer in 

10 the data center, but sometimes we have two 

11 transformers in the same cabinet. And one -- you 

12 can see here, one on the top and one at the bottom, 

13 they’re in the same cabinet.

14 And if you look at the next picture, you 

15 will find out there are two transformers side by 

16 side that makes cooling a little difficult. I’m 

17 sorry -- okay? If you look at those two in that 

18 picture, you can see the transformer at the bottom, 

19 and a transformer at the top, and this is looking 

20 from the back side of the unit, and the cooling is 

21 only on the back side of the unit. There is no 

22 cooling on the sides and there is no cooling in the 

23 front. 

24 The front, if you look at the next picture 

25 -- I think they went in the other direction -- yes. 
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1 You see there are two transformers again, side by 

2 side in this one. And if you look on the top, there 

3 are breakers and breakers need to be isolated from 

4 the heat coming out from the transformers, otherwise 

5 they will prematurely trip. We can go to the next 

6 picture.

7 This is the front of one of the PDU units 

8 and you can see that a panel was one on the top and 

9 one on the bottom, and there is a metering, and 

10 there is another panel board below the metering 

11 also. And there is no way we can cool the 

12 transformer from the front. There is a barrier 

13 between the panel boards and the transformers. 

14 Next.

15 We are going to a little different -- this 

16 is to tell you how the small manufacturing look, a 

17 typical one. This is our core cutting area. What 

18 you are facing is there are coils of the core 

19 material and next to that there is the yellow 

20 screens are the core cutting machines. Next.

21 This is our assembly area looking from one 

22 end to another end. There is a gentleman standing 

23 there with a white shirt assembly the core, the core 

24 legs, and they go down there and further down he’s 

25 assembling the yoke and the core legs together and 
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1 that is miter cut core on that one he’s assembling. 

2 Next picture.

3 Here is the winding machines. We use a 

4 very sophisticated winding machines for winding the 

5 foil (ph) windings. A lot of this data center 

6 transformers have a foil winding at the low voltage 

7 as well as the high voltage to have a better cooling 

8 and reduce the ... and the stray losses.

9 This is the area showing our fabrication 

10 shop. We do enclosures there and also the punching 

11 machine -- automatic punching machine, brakes and 

12 all those kind of things. 

13 Here is the assembly of our data center 

14 units, the PDUs, and you can see there’s hardly any 

15 room to work over there. Next.

16 And here again we are going back to the 

17 core cutting machines that are another view of that. 

18 Here is again data center unit assembly area, and 

19 there are different units.

20 Here is our test department. On the 

21 transformers you are seeing in the test area are not 

22 varnished. They are tested with all the test 

23 required for UV requirement as well as the NC and UL 

24 requirement and there after they’re varnished and 

25 final tested again when they are put in the 
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1 enclosure. The reason for testing those 

2 transformers in this condition, before varnish, if 

3 something is wrong with the transformer we can 

4 always open and repair it. The transformer you see 

5 with the big transformer there on the right hand 

6 side is actually a UPS transformer used in the UPS 

7 cabinet for rectifier. It’s a 12 volt rectifier 

8 transformer. Next picture.

9 And again, this is another view of the 

10 test area. This is a coil winding area. This is 

11 just a view of the shop with the test area in front.

12 Here is the data center transformer 

13 assembled, and you see looking at the back side of 

14 it, and the transformer BUS box primary and 

15 secondary are welded to the BUSes going to the 

16 breakers and the panel boards. The reason for that, 

17 there is no access to the back of the unit, and we 

18 do not want any voltage joints in that area to be 

19 maintained. So all of the things are welded and you 

20 cannot take that transformer out, you have to take 

21 the whole PDU out to replace it. And because of 

22 that, we have to make sure the transformer is very 

23 reliable. All the data center transformers have at 

24 least minimum of two shields between the secondary 

25 and the core and also between the secondary and the 
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1 primary, that increases the insulation required 

2 because there is insulation between the shield and 

3 the secondary, and insulation between the shield and 

4 the core, as well as the insulation between 

5 secondary and the shield on the high voltage side 

6 and also the insulation from the shield to the high 

7 voltage winding. That’s one of the reasons this 

8 transformer also become very costly.

9 This is area -- you will see this is all 

10 the metering, monitoring of the equipment and the 

11 controls of the breakers on the panel boards, and 

12 the remote monitoring of the loads on the breakers 

13 and all those kind of things. Next please.

14 This is data center transformer, another 

15 one, which does not have a panel board, but if you 

16 look at the very bottom, there is an input breaker. 

17 Above that is a main secondary output breaker, and 

18 there are eight breakers on the top which is going 

19 to the panel boards at the remote locations in the 

20 data center.

21 This is another view of the different 

22 transformer, and you can see all the BUSes are 

23 welded there.

24 This is what is the data center 

25 transformers normally do, and let me see -- we have 
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1 put down some kind of stake for this thing as to how 

2 we define the data center transformers, and in that 

3 we said, up to K13 for transformers of the 300 KVA. 

4 K-9 for 750 KVAs, and K-4 for a transformer over 750 

5 KVA. 

6 This is the minimum requirement and that 

7 has to be verified by a third party like a UL or 

8 anybody -- an RTL kind of thing. You can’t just put 

9 a label like that, we have to be verified. 

10 Transformers to have minimum of two or more shields, 

11 and item number three, we are talking about we had 

12 to put an instruction plate which is not requirement 

13 but we are thinking that it should be put an 

14 instruction plate that this transformer is designed 

15 for the IT kind of thing, and it’s unlawful to use 

16 for any other purposes. 

17 We normally put on our transformers, 

18 although it is not required, on the TP-1 transformer 

19 that this is a distribution transformer and this 

20 meets the requirements of DOE. Other transformers 

21 which are not under the current DOE regulation, we 

22 put a nameplate telling this is a transformer to be 

23 used with the UPSs and everything, and it is 

24 unlawful to use for any other purposes. So we put 

25 that on all although it is not a legal requirement.
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1 In addition to the clear requirements we 

2 put up front, on the top, fourth one is one of the 

3 following requirements has to be there to qualify as 

4 a data center transformer. And that is ... inrush 

5 current four times or less of the full load current. 

6 Temperature rise 130 degrees Centigrade or less. 

7 Primary winding and a secondary winding -- both 

8 windings having interwinding connections other than 

9 delta are Y. We are normally getting lot of 

10 requests of -- and we are selling the transformers 

11 which has got two secondary windings and they’re 

12 face-shifted 30 degrees apart from each other so 

13 that the harmonics are reduced, reflected to the 

14 primary and to the utility.

15 MR. PATZNER: Thomas Patzner, Schneider 

16 Electric. This is the -- Point C is the potential 

17 point to differentiate them from distribution 

18 transformers. Vijay is outputting two voltages, but 

19 they’re equal so that’s why we couldn’t use the 20 

20 percent TAP exception that exists today, because 

21 both voltages will be equal, even though there’s two 

22 separate windings. Normally when we have two 

23 separate outputs on the transformer, the voltages 

24 are different, which is part of that 20 percent, 

25 exception for TAPs where when we would add a 
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1 completely separate winding it’s almost always for a 

2 second voltage. In this case, Vijay’s adding the 

3 entire second voltage output and face-shifting it 

4 for the data center, so it’s different, but because 

5 it’s at the same voltage it doesn’t fall into one of 

6 the existing exclusions, but it has losses and so 

7 forth.

8 MR. TENDULKAR: Losses and costs, both.

9 MR. PARKER: Rob has a question.

10 MR. GREESON: Rob Greeson, Federal 

11 Pacific. The definition of a distribution 

12 transformer says, a secondary. You’re talking two 

13 secondaries?

14 MR. TENDULKAR: Yes.

15 MR. GREESON: It’s exempt. That’s the way 

16 I interpret it.

17 MR. TENDULKAR: Well, one of the --

18 MR. GREESON: So if it’s got two 

19 secondaries is it not already exempt -- that 

20 particular type?

21 MR. TENDULKAR: It was not very clear when 

22 I looked at it. We’re looking at a word “a” only 

23 and then say yes, only one secondary. But there is 

24 no clear assumption written down that with more than 

25 one secondary in the one ...
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1 Anyway, coming back -- go ahead.

2 MR. FERNSTROM: Vijay, Gary Fernstrom, 

3 PG&E. I have a question too. You were making the 

4 point that these transformers need to deal with a 

5 lot of harmonics on this secondary, and they 

6 consequently dissipate some energy. Can’t harmonic 

7 filters be used and if not, why not, to reduce the 

8 harmonics actually needing to be dissipated in the 

9 secondary?

10 MR. TENDULKAR: Harmonic filters can be 

11 used and they -- many are more and more equipments. 

12 You need more and more space, and again, they have 

13 more and more losses kind of things. Harmonics 

14 filters a lot of losses too. And harmonic filters 

15 are not as reliable as the transformer is. We make 

16 inductors for the harmonic filters for the UPS 

17 industry, and as you know, the harmonic filters have 

18 a capacitance and the inductors. And normally these 

19 are series connected devices, filters, and the 

20 capacitor starts failing. If one capacitor fails it 

21 tunes the frequency to higher frequency, and 

22 eventually even the reactor fails. This has 

23 happened quite often. And that’s the reason we try 

24 normally not to use the filters in this kind of 

25 area. The reliable power requirement, we don’t want 
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1 to use the filters.

2 MR. FERNSTROM: Okay. Thank you.

3 MR. TENDULKAR: Item D is there are two --

4 MR. PARKER: If I could just recap for a 

5 second. In response to Rob’s question about whether 

6 these data center transformers may be already 

7 exempt, your response was?

8 MR. TENDULKAR: We did not take any 

9 exemption because there was no clear cut wording to 

10 that effect.

11 MR. PARKER: Rob, did you want to come 

12 back?

13 MR. GREESON: Rob Greeson, Federal 

14 Pacific. Let me understand this. The two 

15 secondaries -- are you then tying those two 

16 secondaries in parallel with one another? 

17 MR. TENDULKAR: No.

18 MR. GREESON: Or are they going to 

19 separate circuits?

20 MR. TENDULKAR: The two secondaries are 

21 going to two separate loads. They are face-shifted 

22 so they cannot be parallel. It’s something like a 

23 delta and Y connection kind of situation, but both 

24 of them are Y connected, but they are not exactly 

25 simple Y, it is a dog-leg Y kind of thing.
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1 MR. GREESON: Well we’ve not run into --

2 Rob Greeson, Federal Pacific -- this exact 

3 particular thing, but we’ve always interpreted the 

4 definition of a distribution transformers, when 

5 you’re talking about the single-phase where you have 

6 the reconnectable windings, the 120/240, you’re 

7 connecting both those windings together for one 

8 secondary, so it’s not really the same thing as this 

9 is truly more than one secondary. The test 

10 standards aren’t set up to cover it. The definition 

11 says “a secondary.” I would -- if that transformer 

12 came across my desk I would have said it was 

13 exempted based on the fact that it had the two 

14 secondaries on it.

15 MR. TENDULKAR: Thank you.

16 MR. GREESON: That would have been my 

17 interpretation, based on what we know now from the 

18 definition, and -- but that’s what I would say about 

19 that, thanks.

20 MR. PARKER: Tim Ballo.

21 MR. BALLO: Tim Ballo, Earth Justice. 

22 Just to be clear, the definition of distribution 

23 transformer, both in the statute and in DOE 

24 regulations, refers to an output voltage, I’m not 

25 sure where you derive the word secondary from. Or 
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1 the limitation to a single secondary.

2 MR. GREESON: I’m going to bring that up 

3 and look at that. You may be -- if it’s an output 

4 voltage, that’s still singular.

5 MR. PATZNER: But the voltage is the same 

6 on this device -- Thomas Patzner, Schneider Electric 

7 -- so I would interpret that a 2-way Y and a 30 

8 degree face-shift 2-way Y is a output voltage. So I 

9 would have interpreted that it had to comply, 

10 because the voltage is equal, so it’s -- you’re 

11 selling the device to feed two 208 distribution 

12 panels, 30 degrees apart. But if -- if the current 

13 law allows us to allow the 30 degree face-shift 

14 device to already be excluded, it makes this data 

15 center discussion a lot easier, because our major 

16 concern is that it would not substitute a 

17 transformer feeding a distribution panel. If the 

18 data -- when the data centers are feeding two 

19 distribution panels, the marketplace has not 

20 embraced that and don’t know how to substitute it.

21 MR. PARKER: So could -- could Vijay, Rob, 

22 Tim and Tom converse off line after this meeting and 

23 kind of work this out and report to us as soon as 

24 they have an answer, that would be very helpful. 

25 Thank you.
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1 MR. TENDULKAR: Sure do.

2 MR. SMITH: Vijay, Bob Smith. Could this 

3 transformer --

4 MR. PARKER: Excuse me just a second, Bob. 

5 It might have gone without saying, but should not go 

6 without saying, that Dan Cohen at the Department has 

7 a very capable legal staff and may be able to help 

8 with this discussion as well. So you should bring 

9 him into the loop, and I’m sure you will. Go ahead, 

10 Bob.

11 MR. SMITH: Vijay, could this transformer 

12 be considered a rectifier transformer?

13 MR. TENDULKAR: It is constructed like a 

14 rectifier transformer. It could be used as a 

15 rectifier transformer, but it has got standard 

16 distribution voltage of 208 volt or something like 

17 that, and that is -- normally, the rectifier 

18 transformers have a voltages which are normally not 

19 standard voltages. For example, we have got a UPS 

20 transformer, rectifier transformer, primary voltage 

21 is 480 and there are two secondary voltages of 465, 

22 30 degrees face-shifted, to get something like an 

23 800 volt DC. So the rectifier secondary voltages 

24 are based on what the DC BUS voltages are. But yes, 

25 it can be used as a rectifier transformer.
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1 MR. SMITH: As you know, rectifier 

2 transformers are exempt.

3 MR. TENDULKAR: Exactly. You’re 

4 absolutely right. The rectifier transformers are 

5 exempt, but these transformers are not supplying 

6 rectifier -- if you go in a strict legal definition, 

7 they are supplying the panel boards and supplying 

8 the loads which are normal distribution loads in the 

9 data center. So as far as I’m concerned, I’m in a 

10 dilemma how to interpret this. You know, you are 

11 absolutely correct, it is a rectifier transformer 

12 because most of these servers have rectifiers inside 

13 them, but the servers are not considered rectifiers.

14 (Two speaking on phone at same time.)

15 MR. PARKER: Excuse me, we have two people 

16 talking at once. We had two people talking at once, 

17 I couldn’t even make out who is talking.

18 MR. GREESON: Phil Ling and Bob.

19 MR. PARKER: Bob -- why don’t we have Bob 

20 Smith talk first.

21 MR. SMITH: Bob Smith, Federal Pacific. 

22 The harmonics in the load chart are coming from 

23 somewhere, namely some sort of a rectifying device, 

24 whether it’s a variable stage drive or just a plain 

25 rectifier. It seems like you ought to be able to 
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1 get your transformer exempt on the basis of the type 

2 of load that it’s serving.

3 MR. PARKER: Okay. So we have a group 

4 formed to explore that issue. Anybody who has an 

5 interest in this or who has expertise in this, even 

6 if they don’t have an economic interest in it, and 

7 is willing to share it, please communicate with 

8 Vijay, Tim Ballo, and Tom Patzner and Rob Greeson, 

9 and let’s see if we can get a handle on that as 

10 quickly as possible. 

11 Meanwhile, in the event that these are not 

12 exempt, perhaps -- already -- perhaps we can just 

13 spend a few minutes discussing what distinguishing 

14 characteristics of the product might be focused on 

15 to provide a basis for a carve out, assuming that 

16 they are not -- in the event it turns out that they 

17 are not already exempt. Remember, a nameplate that 

18 says it is unlawful to use, don’t help. Discussions 

19 about applications don’t help. There needs to be, 

20 as I understand it, and I’m a lawyer, but not in 

21 this area, but as I understand it, there has to be 

22 something -- a physical distinction in the product 

23 itself that one can point to and one can put into 

24 the standard, and that distinction has to insure 

25 that these units are not used for non-data centers, 
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1 thereby circumventing the purpose of the standard.

2 So if you could just spend a few minutes 

3 addressing that issue, I think it would be very 

4 helpful, and perhaps these A through D do that, but 

5 do they actually prevent circumvention, I guess that 

6 is the question.

7 MR. FERNSTROM: Richard, quick comment. 

8 Gary Fernstrom, from PG&E. I don’t know that 

9 exemption is necessarily the answer. I think we 

10 ought to investigate the extent to which this 

11 special category of transformer can have its 

12 efficiency improved or not. Because, let’s face it, 

13 there’s a lot of load associated with data centers. 

14 It’s increasing. And I’m interested in, you know, 

15 where we are with the efficiency of that product now 

16 and where we could be.

17 MR. PARKER: Fair enough. Even if data 

18 centers might have a higher standard than today, but 

19 not as high a standard as other transformers, that 

20 still raises the question of circumvention, though, 

21 so of course --

22 MR. TENDULKAR: Let me answer that 

23 question to comment one moment. You’re absolutely 

24 right about that. The -- one other thing is we do 

25 not want the harmonics to be reflected to the 
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1 utility, that is one of the things we are interested 

2 in because utilities don’t like harmonics. That’s 

3 one thing. The second part is the data center 

4 transformer which I was going to come back later on, 

5 but I will mention it now, are not typically 

6 cyclically loaded during the daytime. They are 

7 continuously loaded, 24/7, 365 days a year for ten 

8 years, whatever the life of the data center is. And 

9 I was, after I wrote my things, I had given to our 

10 general manager who has designed the data centers 

11 and one of our sister companies, is designing the 

12 data centers, to put in the container -- shipping 

13 containers kind of things. So we know some of those 

14 things. 

15 According to him, they are loaded around 

16 80 percent of the full load capacity. And the trend 

17 is to go towards 100 percent load. I don’t think 

18 they will go to 100 percent load. Now if we deign 

19 the transformer to meet the current efficiency 

20 requirement at the high efficiency of 35 percent 

21 load, that makes the core losses lower and the 

22 winding losses higher, and the winding losses 

23 higher, if you increase the core loss by one watt, 

24 you can increase the winding losses by three watts. 

25 And that has got a big advantage in shifting our 35 
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1 percent load point for efficiency to somewhere 

2 higher, something like a 60, 65 percent, where the 

3 efficiency should be higher. So that’s another 

4 thing we should be thinking about these transformers 

5 in a different light.

6 MR. FERNSTROM: So, Vijay, Gary Fernstrom, 

7 PG&E. Our experience corresponds with what you’re 

8 saying. Many of these new data centers are not 

9 fully loaded when they’re built, but after they’re 

10 built up to full capacity, they are running 60 to 80 

11 percent load.

12 MR. TENDULKAR: The other important thing 

13 about these data center transformers and people 

14 don’t really understand that sometimes, I can design 

15 a distribution transformer as low as about a quarter 

16 inch clearance from the windings to the ground on 

17 the ends. We are normally providing about five18 eighth inches to three-quarter inches clearances to 

19 the ground, and also somewhere else’s. The reason 

20 for that is if the data center transformer fails, 

21 you have dire consequences. The data center, if it 

22 fails, you have to get an alternate source and you 

23 can get it up, even if you have alternative server 

24 immediately, it may take six to eight hours for the 

25 data center to come back again on the line. Just 
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1 imagine I’m leaving this afternoon on American 

2 Airlines and their data center goes down. I may not 

3 be able to fly home today. So those are the 

4 consequences we have to think about when we talk 

5 about the data -- the reliability is very important 

6 on these transformers.

7 PARTICIPANT: You still have Philip on the 

8 line.

9 MR. PARKER: Oh, sorry, Philip.

10 MR. LING: Yes, thank you. I guess a 

11 couple of things. It seems -- we do a lot of 

12 business in the data center world, and there’s 

13 really more than AD to center transformer. Some of 

14 the data center designs, a lot of them, an A BUS, B 

15 BUS, which inherently will never be loaded more than 

16 50 percent, or run more typically around 35 percent. 

17 That’s obviously a different scenario than the ones 

18 that get loaded up for 80, 100 and added in the 

19 distribution.

20 The second thing is that -- I mean we’re 

21 shipping -- we shipped all those configurations, a 

22 low end rush, which is obviously a common 

23 requirement for a data center; the dual output 

24 configurations as well, and we’re typically shipping 

25 EL-2 level performance 100 KVA and above. So it’s 
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1 not a problem to do.

2 The other thing is in terms of harmonic 

3 profile, there’s a big variance in terms of harmonic 

4 profile in there. A lot of the servers currently 

5 being used are less than ten percent current 

6 distortion which is about a K1.2 or 1.3. So a lot 

7 of legacy requirements or specification like a ... for 

8 high K factor transformers, but a lot of the new 

9 data centers going in where specification is calling 

10 for K-4 aluminum. The transformers are outside the 

11 data center floor, and they’re acknowledging that a 

12 ten percent current load distortion environment. 

13 So there’s not one data center, one 

14 application, there’s a variety of situations. 

15 What’s in common is we are able to deliver high 

16 efficiency across all of those markets, even in the 

17 multiple ... transformers.

18 MR. PARKER: Tom, would you like to 

19 respond?

20 MR. PATZNER: Thomas Patzner from 

21 Schneider Electric. I concur that there is multiple 

22 designs. I asked for a document from Schneider 

23 Electric to be uploaded to the Sharepoint, and in 

24 the summary it’s going to say that there’s at least 

25 50 different ways data centers choose to use 
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1 transformers. We, as a company, recommend ten 

2 different configurations today, and that document 

3 actually goes through all the different potentials. 

4 And as a company chooses to do a data center, they 

5 choose what is best for their outputs in which way 

6 to use the transformers. I think that’s been the 

7 biggest issue with trying to break out the data 

8 centers to come up with the definition, is the fact 

9 that the data center market, depending on if you’re 

10 talking to Microsoft, or if you’re talking to a 

11 manufacturer, or a company who’s putting in the data 

12 center themselves, the way that the transformer 

13 needs to be designed is different. 

14 The document’s up on the slide right now. 

15 If you just go to the very last page, I think it’s 

16 the second to the last. So here’s the conclusion 

17 and as you can see, the paper has identified over 50 

18 different arrangements of transformers that can be 

19 used in a UPS system. Ten are identified as 

20 preferred solutions. Now, once again, that’s 

21 Schneider Electric’s opinion of those preferred 

22 solutions. But if you go through these 26 pages 

23 you’ll see the different ways that transformers can 

24 be done, and that’s the biggest concern is some of 

25 these ways are using off-the-shelf distribution 
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1 transformers. So from our perspective, when they’re 

2 choosing -- the configurations that choose to use 

3 off-the-shelf distributions need to still be in 

4 compliance. It’s when we get into the designs that, 

5 like Vijay has, with the dual output, that there is 

6 the potential need to address them differently. 

7 Thank you. 

8 MR. TENDULKAR: This is Vijay --

9 MR. LING: This is Philip at Powersmiths. 

10 Just sort of a last comment in there, is I think 

11 unlike the commercial environment, the data center 

12 environment, because it’s not just that it runs 

13 7/24, but pretty much if you look at the data, it’s 

14 a watt of cooling per watt of heat loss. So when 

15 you think of exempting or lowering the threshold of 

16 requirement in that market, that’s a market with a 

17 great pay-back. The rate interest in squeezing out 

18 watts out of their system, because it’s a one-for19 one, or two-for-one -- every watt of reduced 

20 transformer loss is two watts, because you get the 

21 cooling watt as well. So there’s a whole green grid 

22 organization -- there’s a whole greening of the data 

23 centers is moving very quickly, so I wouldn’t exempt 

24 it, and transformers ...

25 MR. TENDULKAR: This is Vijay from Onyx 
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1 Power. I totally agree with you that the 

2 transformer losses have to be taken out, but the 

3 cooling system in the transformer has got more 

4 losses, and the cooling system has to work harder, 

5 so you need a bigger cooling system. But, again, 

6 each data center is different, and we are dealing 

7 with also the people who are asking for the 

8 transformers with the high K ratings. At this 

9 moment, I’m designing 1000 KVA with K-13 load power 

10 kind of thing. Now, if the customer specifies that 

11 he wants 1000 KVA K-13, we have to provide him with 

12 that transformer and that transformer has to be 

13 tested to the UL 561 standard to provide those kind 

14 of losses and still be cooled at whatever the 

15 temperature rise we set. It is a 130 degrees rise 

16 transformer.

17 Now, that kind of transformer is very 

18 difficult to design and still meet the TP-1 

19 efficiency with the 400 magnetizing current.

20 MR. PARKER: Andrew.

21 MR. DeLASKI: This is Andrew, and I feel 

22 like we’re kind of getting at a plenary session here 

23 and pretty foreign to the details that are quite 

24 important. But what I’m hearing, what I’m taking 

25 away from this conversation is that this initial 
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1 rubric of data center transformer was just too 

2 broad. So what we need to do is identify what are 

3 the engineering characteristics of these products 

4 that make them highly specialized, to provide a 

5 highly specialized need, and that can be identified 

6 in a product. And that’s different than simply the 

7 term “it’s a data center transformer.” It’s 

8 something different. And that’s not saying what 

9 that something is right here today, that’s what we 

10 have this technical subgroup to work on.

11 MR. PARKER: Yeah. 

12 MR. TENDULKAR: Let me answer that again. 

13 In the beginning, I put down some conditions, and 

14 you had to meet those conditions to qualify the data 

15 center transformer. If the load is a K-1 or a K-2 

16 or something, and you’re making a transformer from 

17 that, it will not be qualified as a data center 

18 transformer, because your K factor of that 

19 transformer is less than what is specified in those 

20 conditions. It has to be K-20 at the -- below 300 

21 KVA, K-13 for 300 KVA, -- I’m sorry, K-13 up to 300 

22 KVA. If you have less than that, it is not a data 

23 center transformer. Those are the minimum 

24 requirements we have.

25 MR. PARKER: Well, I think --
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1 MR. DeLASKI: I’m not a designer. I’m 

2 looking to you guys to --

3 MR. TENDULKAR: Yeah, I understand that. 

4 I understand that. I was just answering the 

5 previous question .

6 MR. PARKER: Right. I think we need to --

7 I think we’ve gone -- well, Wes, do you have 

8 something very quickly?

9 MR. PATTERSON: Yes, I’d also like to 

10 mention that this discussion also plays over on 

11 medium voltage dry type. It’s not restricted to low 

12 voltage. Everything that he’s talking about also 

13 applies to 5 and 15 KVA transformers. So one 

14 question that I would have is what is the market 

15 size that we are talking about here? I’ve not heard 

16 it in the discussion anywhere.

17 MR. TENDULKAR: I do not know the market 

18 size at this moment, but I do not think it is a very 

19 big market size, compared to total distribution 

20 market.

21 MR. DeLASKI: And again, a little 

22 inconsistency on that, because in the last meeting, 

23 the number was put forward as some very significant 

24 percentage of US power use goes to power data 

25 centers. Right. So, and one of the industry 
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1 representatives last time put out quite a large 

2 number, and I think that’s consistent with some of 

3 the work done on the greening data centers, is that 

4 there is a lot of power being used by data centers 

5 in the United States. The question is, what portion 

6 of that is being used by the distribution 

7 transformers -- or the transformers that are being 

8 proposed to be exempted, or to have a lower 

9 standard, and what portion is being used by ones 

10 that are proposed to be covered. That’s kind of the 

11 thing we have to disaggregate.

12 MR. PATZNER: Thomas Patzner from 

13 Schneider Electric. There’s been a lot of work on 

14 the amount of power that goes to data center. The -

15 - if we can get the same split as we did with the 

16 commercial building, where we see how much is going 

17 to lighting, how much is going to HVAC, all the rest 

18 will be feeding the servers. And the portion that’s 

19 feeding the servers is going to 100 percent flow 

20 through the transformers. So, if they have the 

21 splits, which I think they should because they break 

22 up, for commercial buildings they have HVAC, they 

23 have lighting, and then they have other, and in data 

24 center markets, the other is the servers. They 

25 don’t put any other devices in the building. So it 
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1 would be easy to get the amount of energy that has 

2 to be flowing through the transformers. And then if 

3 we assume the transformers are three percent loss, 

4 we can determine what the energy impact would be.

5 MR. PARKER: So, thank you. I think we 

6 need to conclude our discussion of data centers with 

7 that. And I think the charge for the group is 

8 pretty clear, it’s to 

9 • give us the information that you can get on the 

10 size of the market; 

11 • it’s to provide some technical specifications 

12 that distinguish the products that you want a 

13 special standard for from off-the-shelf 

14 products; 

15 • and a demonstration to the satisfaction of the 

16 other experts around the table at least, that 

17 this will -- that these specifications will 

18 insure that these transformers are not used in 

19 non-data center applications.

20 • And finally, a proposed differential standard, 

21 which may be zero, may be above zero, but what 

22 special treatment you would propose.

23 We have a call now set up for December 

20th 24 . We would need your report, I think, several 

25 days in advance of that call in order to be able to 
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1 take it on board, so I think we should aim for 

December 14th

5 If we have that and it meets the legal 

6 requirements, I think we’re in business and we can 

7 attend to that fairly expeditiously on the call. 

8 And if we don’t, we can’t. It’s about as simple as 

9 that. So with that, I think, unless there’s 

10 anything else that we urgently need to cover now, we 

11 can conclude. John.

2 for receiving your report so that we 

3 could have some discussion and so there could be 

4 some adjustments to the report.

12 MR. CASKEY: John Caskey, NEMA. Just a 

13 quick question. Is there somebody that’s going to 

14 work with this group, mostly manufacturers plus Tim, 

15 from Navigant or LBL that can help with the market 

16 size?

17 MR. PARKER: Mike? Is there somebody from 

18 Navigant that can help with this issue? About the 

19 market size? Mike will furnish a resource for the 

20 group.

21 MR. RIVEST: LBL might already have the 

22 data.

23 MR. PARKER: Great. Thank you. A useful 

24 discussion, thank you everybody for coming, and 

25 putting your cards on the table with the last day 
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1 and a half, or I guess it’s just been a day. But 

2 it’s been very helpful, very productive. It’s been 

3 great working with you all. I’m not sure if we’ll 

4 meet in person again, but I really enjoyed the 

5 chance to meet you all and I hope that we can work 

6 out the remaining issues and arrive at a consensus 

7 conclusion at the end of the day, hopefully on 

December 20th

9 So thank, everybody, have a very enjoyable 

10 lunch. Enjoy Washington on a beautiful day if your 

11 plane schedules allow it and we’ll see you later. 

12 Take care.

8 , or very shortly thereafter. 

13 (Whereupon, at 12:40 p.m., the meeting in 

14 the above captioned matter was adjourned.) 

15

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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 LV 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 9, 2011