From: Kenneth Winder [mailto:kwinder@mleainc.com] Sent: Thursday, September 22, 2011 7:36 PM To: Rosenstock, Steven Cc: Richard Parker; Corkran, Jerry L; Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; john.caskey@nema.org; jo hn.cymbalsky@ee.doe.gov; adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; bruce.r. hirsch@bge.com; mhyland@appanet.org; dave.millure@metglas.com; snadel@aceee.org; wes.pa tterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@ nrdc.org; robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelener gy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Michae l Rivest; Jerry Hodge; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron; Daniel.Cohen@hq.doe.gov; jmau er@standardsasap.org; greg.coulter405@gmail.com; bsmith@federalpacific.c om; pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; ahofmann@publicpower.org; Berman Economics@gmail.com; Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org; chad.kennedy@us.schneider-electric.com; eduardorobles@eaton.com; vijay.tendulkar@on yxpower.com; carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider-electric.com; Marusine c, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer Subject: Re: Distribution Transformers Committee reques ted areas for the DOE to Investigate before final rules are selected.

On 9/22/2011 5:11 PM, Kenneth Winder wrote:

Mr. Parker and others,

Below are comments for the modeling, studies and considerations to help in this negotiated Rulemaking process.

Comments about the effects of transformer loading on a distribution pole : A statement of record was made in the September Rulemaking Committee meeting that vertical weight on a pole (from a transformer) can be ignored. I believe this is incorrect and have found some engineering data and calculations concerning the effects of the application of transformers as a tran sverse and vertical load on a pole. It sets forth the calculation methods of the fo rces involved and eventu ally arrives at allo wable loads that can be attached to a distribution pole of various heights and classes. The work shown and conclusions reached in that paper need to be modified to represent an amorphous core transformer since that type of tr ansformer is larger physically and is offset further from the pole than the calculations found, they need to be recalculated for the amorphous transformer application.

I believe this information should become part of the public record. I need to look further into any copyright on the information be fore it can be sent to the group.

Comments about Amorphous core transformers : We have reviewed th e failure of pole-mounted amorphous core transformers over a twenty year period for our utility. We purchased over 1,700 of them during the early to mid-1990's. We have looked at the amorphous transformers purchased compared to those that are still in service (includes those that are on the warehouse docks and in the field). We have tried to simila rly compare the same for st eel-core transformers.Failure rates appear to differ signi ficantly (higher for Amorphous core units). Is this represented properly in the DOE/Navigant model?

Kenneth A. Winder Moon Lake Electric Assn., Inc.