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UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

MEETING of the MV WORKING GROUP

Volume II

American Public Power Association

1875 Connecticut Ave., NW 12th Floor Washington, D.C. 20009

Thursday December 1, 2011

Facilitator:

Richard Parker University of Connecticut Law School

Host:

American Public Power Association 1875 Connecticut Ave., NW 12th Floor Washington, D.C. 20009

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205

Participants Identified:

Gene Andert REA Magnet Wire

Rick Anderson Fayetteville Public Works Commission

Tim Ballo Earth Justice 1625 Massachusetts Avenue Suite 702 Washington, DC 20036

Scott Beck Lakeview Metals

Robert Berman Berman Economics 1915 Orchid Court Vienna, VA 22187

Chris Brown Cogent Power

John Caskey National Electrical Manufacturers Association

Greg Coulter Consultant Prolec GE

Jim Creevy National Electrical Manufacturers Association 1300 North 17th Street Suite 1752 Rosslyn, VA 22209

Andrew deLaski ASAP 20 Belgrade Ave, Suite 1 Boston, MA 02131

Marianne DiMascio American Standards Awareness Project

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Tom Eckman Northwest Power and Conservation Council

Gary Fernstrom Pacific Gas & Electric Company 13055 Parkhurst Dr Oakland, CA 94619

Chuck Foster Edison Electric Institute

Carlos Gaytan Prolec GE

Robert Greeson Federal Pacific Company

Bruce Hirsch Baltimore Gas and Electric, EEI

Gerald Hodge Howard Industries PO Box 1586 Laurel, MS 39441

Phil Hopkinson HVolt, Inc.

Michael Hyland American Public Power Association

Dave Millure Metglas Incorporated 440 Allied Drive Conway, SC 29526

Steve Nadel American Council for an Energy-Efficient Economy

Wes Patterson ABB, Inc.

Eric Petersen AK Steel

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Ray Polinski Allegheny Ludlum - ATI

James Rakowski ATI Allegheny Ludlum

Steven Rosenstock Edison Electric Institute 701 Pennsylvania Avenue NW Washington, DC 20004-2696

Robin Roy Natural Resources Defense Council 1200 New York Avenue, NW, Suite 400 Washington, DC 20005

Paul Ryan Hitachi Metals America 800 Grand Avenue, Suite AG-6 Carlsbad, CA 92008

Bob Saint National Rural Electric Cooperative Association

Mahesh P. Sampat EMS Consulting 1180 Brookview Dr Athens, GA 30606

Jerry Schoen AK Steel Corporation 705 Curtis Street Middletown, OH 45043

Mike Shannon RSA Magnet Wire

Chuck Simmons Progress Energy

Jim Rakowski Allegheny ATI

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Antonio Trujillo Cooper Power Systems

Kenneth Winder NRECA

Participants from DOE:

Sarah Butler (via webinar)

Dan Cohen (via webinar) General Counsel

John Cymbalsky

Participants from Navigant/LBL:

Mike Rivest Navigant

Matt Nardotti Navigant Consulting

Chris Bolduc Lawrence Berkley National Laboratory Berkeley, CA 94720

Katie Coughlin Lawrence Berkley National Laboratory

Art Rosenfeld (via phone) LBL

Webinar Attendees

Jerry Allen Metglas, Inc.

Pam Costello Navigant Consulting

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Charles Drexler Ky. Assoc. of Electric Coops. Brian Kaja General Electric

Richard Lyke AK Steel

Dhiru Patel Hammond Power Solutions Inc.

Tom Petrosino TRP Consulting

John Rosetti Memphis Light Gas and Water

Jeff Schneider Cooper Power Systems

Thomas Patzner Schneider Electric

Bob Smith Federal Pacific

Luo Zhimei Navigant Consulting

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AGENDA

ITEM PAGE

Welcome, Mr. Parker 211

Self-Introductions 211

Discussion of the Medium Voltage Dry Type Transformer Market 218

Final Discussion and Straw Poll 260 Proposal for Next Step 264

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1 9:10 a.m. 2 P R O C E E D I N G S 3 MR. PARKER: Welcome everyone for day two 4 of the medium voltage standard discussions. We had 5 yesterday ... report … a candid and constructive 6 exchange of views. It was a tough day. It was 7 also, by the way, the first day we actually got

8 proposals from everybody. I do not propose to 9 languish on … to turn immediately to medium voltage 10 dry type discussions. I understand there have been 11 some conversations outside so proposals may be 12 advanced, so I think the best way to get the 13 proposals and discuss and -- discuss it briefly, and 14 then instead of trying to do it as a plenary group, 15 think about breaking down into subgroups and 16 caucuses and so forth, to talk about what problems 17 we have, if any, in this case to resolve. 18 Before we get started, let’s go around the 19 table and introduce ourselves. If you’re on the 20 phone, please mute your phones so you don’t get -- 21 use your phones until you give your name and 22 affiliation. Let’s start around the table and then 23 go to the audience, and then the webinar folks. 24 Self-introductions 25 MR. PARKER: I’m Richard Parker,

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1 facilitator, University of Connecticut law school. 2 MR. HYLAND: Mike Hyland, American Public 3 Power. 4 MR. SIMMONS: I’m Chuck Simmons, Progress 5 Energy and EEI. 6 MR. SAINT: Bob Saint, NRECA. 7 MR. HIRSCH: Bruce Hirsch, Baltimore Gas 8 and Electric with EEI contingent.

9 MR. ROSENSTOCK: Steve Rosenstock, Edison 10 Electric Institute. 11 MR. CASKEY: John Caskey, NEMA. 12 MR. ANDERSON: Rick Anderson, Fayetteville 13 Public Works Commission, APPA. 14 MR. POLINSKI: Ray Polinski, ATI Allegheny 15 Ludlum. 16 MR. PETERSEN: Eric Petersen with AK 17 Steel. 18 MR. PATTERSON: Wes Patterson, ABB. 19 MR. GREESON: Rob Greeson, Federal Pacific 20 Transformer. 21 MR. DeLASKI: Andrew DeLaski, Appliance 22 Standards Awareness Project. 23 MR. NADEL: Steve Nadel, American Council 24 for an Energy-Efficient Economy. 25 MR. MILLURE: Dave Millure, Metglas.

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1 MR. HODGE: Gerry Hodge from Howard 2 Industry. 3 MR. COULTER: Greg Coulter, consultant for 4 Prolec GE. 5 MR. GAYTAN: I’m Carlos Gaytan, Prolec GE. 6 MR. FERNSTROM: Gary Fernstrom, PG&E 7 representing PG&E, SCE and Semper Utilities, as well 8 as west coast perspective. 9 MR. ECKMAN: Tom Eckman, Northwest Power 10 and Conservation Council. 11 MR. CORKRAN: Jerry Corkran, Cooper Power 12 Systems. 13 MR. BECK: Scott Beck, Lakeview Metals. 14 MR. BALLO: Tim Ballo, Earth Justice. 15 MR. ROY: Robin Roy, Natural Resources 16 Defense Council. 17 MR. RIVEST: Mike Rivest, Navigant 18 Consulting. 19 MR. CYMBALSKY: John Cymbalsky, DOE. 20 MR. BOLDUC: Chris Bolduc, Lawrence 21 Berkley National Labs.

22 MS. COUGHLIN: Katie Coughlin, Lawrence 23 Berkley National Labs. 24 MS. DiMASCIO: Marianne DiMascio, 25 Appliance Standards Awareness Project.

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1 MR. NARDOTTI: Matt Nardotti, Navigant. 2 MR. SAMPAT: Mahesh Sampat, EMS 3 Consulting. 4 MR. BROWN: Chris Brown, Cogent Power. 5 MR. ANDERT: Gene Andert, Rea Magnet Wire 6 Company. 7 MR. SHANNON: Mike Shannon, Rea Magnet 8 Wire Company.

9 MR. SCHOEN: Jerry Schoen, AK Steel.

10 MR. RYAN: Paul Ryan, Hitachi Metglass. 11 MR. TRUJILLO: I’m Antonio Trujillo from 12 Cooper Power Systems. 13 MR. WINDER: Ken Winder, NRECA. 14 MR. MEYERS: Aaron Meyers, Cooper Power 15 Systems. 16 MR. RUSH: Ned Rush, consultant.

17 MR. CARMICHAEL: Rob Carmichael, Navigant. 18 MR. COFFEY: Brian Coffey, Navigant 19 Consulting. 20 (inaudible) 21 MR. TENDULKAR: Vijay Tendulkar, Onyx 22 Power. 23 MR. BERMAN: Robert Berman, Berman 24 Economics.

25 (inaudible)

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1 MR. CREEVY: Jim Creevy, NEMA. 2 MR. RAKOWSKI: Jim Rakowski, ATI Allegheny 3 Ludlum. 4 MR. FOSTER: Chuck Foster, counsel for 5 EEI. 6 MR. HOPKINSON: Phil Hopkinson, last, 7 HVolt, Inc. 8 MR. PARKER: Okay. On the phone?

9 MR. ALLEN: Jerry Allen, Metglas. 10 (introductions on phone not clear) 11 MR. FINE: Greg Fine (ph), AK Steel.

12 MR. PETROSINO: Tom Petrosino, Prolec GE. 13 MR. PATZNER: Tom Patzner, Schneider 14 Electric. 15 MR. DREXLER: Charlie Drexler, Kentucky. 16 Association of Electric Coops. 17 MR. PARKER: Anyone else on the phone? 18 MR. ROSETTI: John Rosetti, Memphis Light 19 Gas and Water. 20 MR. SMITH: Bob Smith, Federal Pacific. 21 MR. PARKER: Anybody else on the phone? 22 Okay. Thank you. And thanks again to Mike Hyland 23 and the American Public Power Association for 24 hosting us today. I hope you all got some sleep 25 last night.

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1 So we’re going to tackle medium voltage 2 dry types. I know that for various reasons we have 3 in this committee a number of participants who don’t 4 have a direct stake in this, the utilities, and may 5 or may not want to sit in on all of this. I spoke 6 with … get this idea to work and he assured me that 7 it would. Basically, for those people -- everybody 8 here … process and for those people who do not wish

9 to sit in on this because they or their organization 10 don’t have a problem to raise, they are perfectly 11 willing, and in fact encouraged to sit -- abstain at 12 the end and take a break. It you don’t want to sit 13 in on the discussions you can go wherever you like 14 and at the end, at the vote, just cast an abstention 15 or no vote, if that’s your choice. 16 On the other hand, if you wish to 17 participate, you’re obviously on the committee, and 18 you’re more than welcome to participate. But I 19 don’t want people around the table because they’re 20 on this committee and there’s nothing in our rules

21 that require that they -- that’s your choice. 22 So, with that in mind, please let’s turn 23 to the discussion of the medium voltage dry type 24 transformer market. And we’ll start with proposals 25 and then have a brief discussion about the

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1 proposals. Steve, you have a question. 2 MR. ROSENSTOCK: Steve Rosenstock, EEI. 3 Just real quick, just trying to look at the 4 presentations that were done by Navigant that were 5 distributed. The ones I have are dated November 6, 6 November 8th, and November 28th. I’m sorry Steve 7 Rosenstock, EEI. In terms of the dry type the most 8 recent ones I have would be November 6, 2011,

9 November 8, 2011, and then one that was e-mailed or 10 I got on the Sharepoint was November 28, 2011. I 11 can read the titles if you want. November 28th was 12 default scenarios, exclusion scenarios. Again, just 13 from my review, are those three presentations that 14 they have? 15 MR. BOLDUC: Chris Bolduc, LBL. The most 16 recent engineering data is in the November 28th 17 version. That you should use as your reference. 18 And you can look at eleven -- from 11/15 version. 19 MR. ROSENSTOCK: I didn’t print it out. 20 MR. BOLDUC: Okay. And that was presented 21 in the Webinar. So please use that for the 2010 22 prices. 23 MR. ROSENSTOCK: Thank you very much. 24 MR. PARKER: Any other questions about the 25 analysis? People have had it, have had a chance to

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1 look at it. Who would like to present the proposals 2 first? 3 MR. GREESON: Would it be possible for the 4 NEMA members to have a brief discussion before we 5 present this proposal? 6 MR. PARKER: Absolutely. 7 MR. GREESON: Maybe ten minutes. 8 MR. PARKER: Absolutely. Let’s recess for

9 ten minutes. Ten, 15 minutes? Let’s say 15, give 10 you time. Coffee and refreshments out there for 11 those of you who just arrived. We’ll meet back in 12 15 minutes. 13 (Whereupon, at 9:20 a.m., the meeting was 14 off the record for a 31-minute period to allow for 15 caucusing.) 16 MR. PARKER: Take your seats please. We 17 are now ready for the proposals. 18 Discussion of the Medium Voltage Dry Type 19 Transformer Market 20 MR. CASKEY: This is John Caskey from NEMA 21 and I’m not sure we’re 100 percent ready but we’re 22 getting close. First of all, I apologize for the 23 delay, certainly on behalf of NEMA, everything that 24 we do needs to be like consensus perspective from 25 our own membership, which is sometimes difficult to

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1 obtain because we do have a diversity of 2 manufacturers and other issues within our own 3 membership. 4 MR. PARKER: I can’t believe attaining 5 consensus can be hard. 6 MR. CASKEY: Yes, consensus can be 7 difficult. But I apologize again for the delay. 8 Yesterday, I think it was yesterday, that we gave

9 our proposal relative to liquid filled, and I gave 10 sort of a spiel on why we really appreciate the 11 opportunity to thank DOE and the members who are 12 here, and I basically ditto on all that stuff. 13 The other thing that I focused on was the 14 three basic principles that we’ve talked about as 15 really -- we want to, you know, number one was we 16 were willing to go higher, we supported going higher 17 with energy efficiency standards, provided that they 18 were cost-effective. 19 The second bullet was related to the 20 substitution of materials. We wanted to make sure 21 that whatever we decided as a group basically 22 there’s a variety of steels to meet that requirement 23 as well as a variety of manufacturers and steel 24 suppliers that could meet those requirements, as 25 well as if there’s some flexibility of design to go

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1 from copper to steel or aluminum or whatever the 2 case may be, but some sort of flexibility in the 3 designs across the manufacturers So that was 4 another thing. 5 And then the other thing was the impact on 6 the small manufacturers. 7 So basically where we’re at NEMA with 8 regard to the medium voltage dry type is one, to be

9 honest with you, we have more discomfort with the 10 Navigant and LBL analysis than in some of the other 11 areas. So fundamentally we have not been able to 12 get to a good point where we can say, gee, we’re 13 close enough or we’re in the right ball park. And I 14 think Wes has done a lot of work trying to explain 15 that and basically, fundamentally, the slip of the 16 curve data points between what we, as manufacturers 17 have, and what Navigant is showing, is different and 18 I think Wes has been trying to work to get that 19 resolved. And Mike has been very helpful and I 20 think, open, in trying to figure out what that 21 tipping point might be. As of today, I don’t think 22 we’ve resolved what that difference might be. So we 23 feel less sort of comfortable with the cost- 24 effectiveness answers. 25 So with that, we have gone back and looked

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1 at the logics … and things like that as far as that 2 is factored into our analysis. But all that said, 3 the bottom line is that what we’re proposing really 4 comes from where we think there is still reasonable 5 substitution of steels and a competitive market and 6 beyond these numbers that I’m giving you, we feel 7 that the market sort of breaks down and we don’t 8 have a good open, competitive market.

9 So the numbers that I have in front of me 10 here is: 11 • For DL-9, we’re proposing 1.5 12 • For DL-10, we’re proposing 2.0 13 • For DL-11, we’re proposing 2.0 14 • For DL-12, we’re proposing 3.0 15 I think the DL-11 and 12, at least, 16 correlate to what the advocates have 17 recommended so far, as I understand it. 18 • For DL-13, we’re basically - I think we prefer 19 to be unchanged from the 2010 rule, but in 20 reality what we’re trying to pave off of is the 21 DL-12, and we don’t know the number in front of 22 me here, but what we want to do is allow for 23 DL-13, which is basically the high BILs, to 24 have ten percent more losses than the 25 equivalent of DL-12. We just don’t know

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1 exactly what that number is, and we’ll work 2 with the other members at the table to try to 3 figure out exactly what that is. 4 MR. PARKER: Ten percent more losses than 5 DL-12, you’re saying? 6 MR. CASKEY: Than DL-12, and the 7 equivalent of DL-12. So basically, some relief for 8 the high BILs. We’re saying that’s ten percent

9 relief, if you will. 10 The other sort of exception or point that 11 we want to raise deals with the single-phase, and 12 it’s sort of -- well, we’ve said all along that 13 there’s this -- it’s not a strict, normalized 14 relationship between a single-phase and a three- 15 phase transformer. It’s more difficult to produce 16 the one than the other. So what we’re saying is for 17 single-phase that we need less loss reductions than 18 the equivalent three-phase, and that, again, we need 19 to come up with some sort of multiplication factor, 20 however we don’t know what that is yet, but we’re 21 happy to work with people around the table to get 22 concurrence on that. 23 So basically I think what we’re saying is 24 we support pretty much what the advocates had 25 proposed so far with the exception of some sort of

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1 special treatment for the high BILs, and some sort 2 of special treatment for the single-phase. 3 MR. PARKER: Great. Thank you. Let me 4 note also that, just looking at the shipments data 5 that I have -- and this is for 2009, but hopefully 6 it is indicative, that I got from the TSD, DL-9 is a 7 very small category, as is DL-10. And -- like 23, 8 257 megavolts (ph) compared to thousands for the

9 others. DL-13 is also -- I mean DL-13 is also -- 10 well, it’s significant, but it’s still not very 11 large. So 11 and 12 is really where the action is 12 in terms of shipments. Comments? Questions? 13 MR. ROSENSTOCK: Quick question. Steve 14 Rosenstock, EEI. Was 13 divided into A and B? 15 Again, I don’t know if that makes a impact on the 16 votes or not. 17 MR. PARKER: Yes. 18 MR. ROSENSTOCK: I just wanted to know if 19 that had any effect on -- 20 MR. PARKER: Do we have a mic over there? 21 MR. ROSENSTOCK: Oh, okay. I’m sorry. 22 Steve Rosenstock, Edison Electric Institute. My 23 only follow-up question was, for DL-13, there was an 24 A and B category, so I didn’t know if that had any 25 impact on the proposal, if they were separate

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1 numbers or issues, just as clarification. 2 MR. CASKEY: This is John Caskey, NEMA. 3 Basically where there were two categories, once you 4 go to the DL-12 level and sort of back off of that, 5 essentially, and I don’t know what that number is. 6 MR. DeLASKI: Can you explain that, John? 7 DL-12 level -- 8 MR. PARKER: Sorry, give your name,

9 Andrew. 10 MR. DeLASKI: Andrew DeLaski. For DL-13, 11 you want to -- just say it again. 12 MR. CASKEY: To be honest with you, I 13 cannot explain it very well. What we are looking 14 for -- I wish I could, but the facts are the facts. 15 So basically, what we’re looking for is ten percent 16 more loss than what’s available in the DL-12 17 category. So we need to go through and look at the 18 watt loss in the DL-12 category, and then that’s a 19 DL-3 level, and then basically allow for ten percent 20 more losses in that calculation. I’ll be happy to 21 turn the microphone over to Wes to see if he can 22 make more sense out of it. 23 MR. DeLASKI: Let me just try something, 24 let me -- so I have a DL-12, at an EL-3, my 25 calculation shows the reduction in losses is 30.7

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1 percent. So then what would it be for the DL-13? 2 MR. PATTERSON: It would be roughly point 3 nine times 30, ninety percent of the 30. Ten 4 percent less. 5 MR. DeLASKI: Twenty-seven reduction in 6 losses for DL-13 is the proposal? 7 MR. PATTERSON: Yes. It should be a ten 8 percent differential.

9 MR. DeLASKI: Which is -- okay. 10 MR. PATTERSON: Somewhere between the two 11 and three. Wes Patterson. As a clarifying 12 statement. The existing standard pretty much set 13 their loss level at the 95 BIL ratings, and the 95 14 BIL ratings is the large sweet spot of the market. 15 The 125 BILs, the higher BILs, are essentially three 16 to four percent higher in losses in the existing 17 standard. I’m not sure how the three to five 18 percent was arrived at, but technically, these 19 numbers should be at least ten percent more losses 20 because of the increased … required to drive that 21 transformer. It’s making the core much larger. 22 MR. RIVEST: This is Mike Rivest. I can 23 confirm that a baseline design line like the G 24 transformer is having to use more advanced steels to 25 meet the standard that …

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1 MR. DeLASKI: Right, so I’m looking at EL 2 to come out to some -- I’m looking at EL, take 13B, 3 which I think is the main one here, and I’m seeing 4 EL-3 is 27.1 percent loss reduction. Is that what 5 you’re seeing? 6 MR. GREESON: This is Rob Greeson, Federal 7 Pacific. What percent efficiency is that? 8 MR. DeLASKI: This is just our chart, --

9 MR. GREESON: 13A or 13B? 10 MR. DeLASKI: 13A was 98.92, 13B was 99.0, 11 EL-3. 12 MR. GREESON: EL-2 by my numbers is 23.6 13 reduction … (not at mic) … want to look at it in 14 terms of the EL -- 15 MR. SMITH: Richard, good morning. This 16 is Bob Smith of Federal Pacific. I would like to 17 offer a comment on the single-phase transformers 18 that John mentioned, if I may? 19 MR. PARKER: Can you hold on just one 20 second so we can finish this conversation that was 21 going on here. 22 MR. SMITH: Okay. That would be great. 23 MR. PARKER: Thank you. We’ll get right 24 back to you. 25 MR. DeLASKI: So on 13B, at what EL?

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1 MR. GREESON: At EL-3, I had 27.1 percent. 2 MR. GREESON: Okay. I have 27 percent, 3 and that 27 percent represents 6200 watts losses. 4 Okay. So we’re proposal then is 6200 watts times 5 1.1, which is 6820. 6 MR. DeLASKI: Okay. Got it. 7 MR. PARKER: Okay. Bob, did you want to 8 comment?

9 MR. SMITH: Yes. Thank you, Richard. On 10 the single-phase medium voltage dry type 11 transformers, many of those are used by electric 12 utilities in high rise downtown condominium and 13 office buildings. We need to be very careful about 14 raising the efficiency of the single-phase 15 transformers for these applications. We call them 16 high-rise transformers because they need to go up 17 and down elevators, and in some cases they have to 18 be taken apart because of their weight and size. 19 These transformers have one very common attribute, 20 and that is they have to be operated at a very low 21 sound level. And regardless of which core steel we 22 use, whether it’s M4, or M3 or whatever, the way we 23 get low sound is to lower the induction level of the 24 transformer core. And as we do that, it makes the 25 product larger. So I just encourage us to be very

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1 careful about what efficiency we pick for the 2 single-phase because it will have the same impact on 3 the electric utilities as the increased size for the 4 network transformers. 5 MR. PARKER: Thank you, Bob. Wes. 6 MR. PATTERSON: On the single-phase units, 7 I don’t believe we discussed the actual level. In 8 the existing standard, the efficiency of a three-

9 phase KVA, let’s use an arbitrary number -- 10 MR. PARKER: Get closer to the mic, Wes. 11 MR. PATTERSON: In a three-phase 12 transformer, let’s use an arbitrary number. Let’s 13 say for 100 KVA three-phase, there’s a standard that 14 is the existing standard says that 100 KVA single- 15 phase will have the same efficiency. We’re indexed 16 to be exactly the same. This is incorrect. 17 Technically, with a dry-type transformer, 18 the losses in the single-phase transformer will be 19 33 percent more because I have this extra amount of 20 core steel in its construction. And this extra loss 21 should be accounted for in the standard. So our 22 proposal would be that for single-phase, whatever 23 the standard is set for three-phase, the losses be 24 increased 30 percent for the single-phase equivalent 25 KVA. So on a 100 KVA three-phase transformer, if it

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1 had 100 watts loss, then for 100 KVA single-phase 2 transformer, I would have 130 watts loss. That 3 would be our proposal. 4 MR. DeLASKI: I’m looking to the 5 consultants. We went through this last time around, 6 I used DLEs (ph) one to the other, is that similar 7 to the first scaling the Department used in the 8 past?

9 MR. PATTERSON: No. 10 MR. DeLASKI: It’s not? 11 MR. PATTERSON: No. This is Wes. What 12 was used in the past was an assumption that the 13 efficiencies had to be equal to prevent 14 circumvention from a single-phase circuit to a 15 three-phase circuit. Given the size of these units, 16 recognizing Bob’s comment, most of them are used in 17 buildings like this. There’s not enough room to put 18 three single-phase units as an option. It’s 19 physically impossible. So they won’t be 20 circumvented by trying to substitute three single- 21 phase for a single three-phase. 22 MR. SAMPAT: Mahesh Sampat. Remember the 23 standards, it’s not … single-phase … at the same 24 efficiency. It’s connecting a single-phase at 300 25 KVA would have the same efficiency. Correct me if

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1 I’m wrong. 2 MR. PATTERSON: No, I agree with that 3 also. Our proposal is there’s 30 percent 4 differential for the same KVAs. 5 MR. SAMPAT: Okay. So I think that’s what 6 -- 7 MR. PATTERSON: Whatever the end resulting 8 numbers are, we need this 30 percent differential.

9 MR. SAMPAT: Right. On the same KVA 10 basis. 11 MR. PATTERSON: On the same KVA basis. 12 MR. DeLASKI: So let me just comment that 13 the way I see the numbers and sales, the single- 14 phase is one percent. 15 MR. PATTERSON: Yeah, that’s about right. 16 It’s small. 17 MR. DeLASKI: One percent of the total 18 sales of the medium voltage transformers are single- 19 phase. 20 MR. PATTERSON: It’s less than small. 21 It’s at least less than five. 22 MR. DeLASKI: So taking that into account, 23 you know, this is not what we need to spend a lot of 24 time on. 25 MR. GREESON: Rob Greeson, Federal

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1 Pacific. Given Bob’s comments, though, of high rise 2 and weight, Bob, I guess you’re listening to this, I 3 know -- 4 MR. SMITH: I try to listen. I hope you 5 guys could get closer to the microphone. 6 PARTICIPANT: (on phone) I wish you guys 7 could get closer to the microphone also. 8 MR. GREESON: What I was going to propose

9 is, being a smaller segment of the market, rather 10 than -- and we’re concerned about the weight, could 11 we just agree to leave the single-phase unchanged at 12 this point and not have to go through the process of 13 arguing what multiplier to use and given the 14 uncertainties about the weights of the transformer, 15 and its market share, I think it might expediate the 16 process a little bit. 17 MR. DeLASKI: This is Andrew to follow up. 18 The proposal from NEMA, as I understand it, was 19 losses be increased by 30 percent for equivalent 20 KVA. 21 MR. PATTERSON: For the three-phase. 22 MR. DeLASKI: Low losses equals lower 23 efficiency. And have you guys calculated what kind 24 of change that is, to the EL level? 25 MR. PATTERSON: No, I haven’t.

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1 MR. DeLASKI: So how close is that to no 2 change, Rob, I guess is my question. 3 MR. GREESON: I don’t know. 4 MR. DeLASKI: You don’t know. All right. 5 So -- and we’re not going to go backwards, 6 obviously. We’re not allowed to go backwards. The 7 standard increase has to be positive. 8 (Discussion off mic)

9 MR. PATTERSON: So we could change our 10 proposal to be -- change our proposal to be either 11 no change or supports the 30 percent differential. 12 MR. DeLASKI: To my way of thinking, I 13 think some increase does make sense, so that we are 14 minimizing the risk of the loophole that was a 15 concern the last time around, that would be my 16 inclination. 17 MR. PARKER: Do we have any other 18 clarifying questions? 19 MR. POLINSKI: Ray Polinski, ATI 20 Allegheny. Yeah, I just wanted to respond to John 21 and NEMA’s proposal, and I want to make a few 22 comments -- I’m speaking here from ATI Allegheny 23 Ludlum perspective. I can’t say I’m speaking for AK 24 as well -- Eric will speak for AK. 25 But first off, as far as this whole medium

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1 voltage dry, we spent so much time on the liquid 2 tweaking the model and working with things, you 3 know, became -- personally became very comfortable 4 with the analysis. It wasn’t perfect, but, you 5 know, in blending industry and the model and working 6 through it, kind of said, hey, the conclusions were 7 very close. We really have not spent a lot of time 8 on this.

9 But, you know, my position, dating back to 10 our group’s conference call on November 17th, we had 11 a conference call on the medium voltage dry, my 12 position has been that the workhorse for this 13 product today, the workhorse for wound core and for 14 liquid filled is M3. The workhorse grade for this 15 market is M4. And so in my view, M4 was a grade 16 that needed to remain competitive to insure there 17 was adequate supply and no shortage of supply. 18 Again, that’s been my position from that conference 19 call on November 17th. 20 Now the problem that I’m having is that if 21 you look at the Navigant data, where M4 remains 22 competitive is kind of a EL-1, kind of across the 23 board. Mostly we’re talking about the design lines 24 11 and 12 where the majority of the volume exists. 25 Now, when I break out -- we haven’t had a chance to

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1 have a debate or discussion about this level, but 2 Wes’ data, again, you know, Wes assures me that 3 these levels here that NEMA is proposing, M4 is 4 competitive. But it’s a big difference from his 5 data to the Navigant data. 6 And I talked with Rob Greeson a little 7 bit, who’s another significant player in this 8 market, and Rob, the last time I talked with Rob he

9 wasn’t sure -- well, I don’t know maybe it’s more M3 10 -- M3 I just don’t think would go through. But 11 these transformers which have a lot of labor 12 involved with stacking laminations, as I say, M4, 13 .27 millimeter thick materials have been the 14 workhorse. 15 So I’m just trying to frame -- I would 16 love -- if Wes’ data is correct, then I would love 17 to get in line with the NEMA recommendations. But 18 right now, based on the 2010 Navigant engineering 19 analysis data, I’m kind of stuck more to the EL-1, 20 consistent with M4 continuing to be a competitive 21 grade, which is -- for this medium voltage dry. So 22 just wanted to go on record with that. 23 MR. PARKER: Thank you. Eric. 24 MR. PETERSEN: I want to ask a clarifying 25 question. On the NEMA proposal -- Eric Petersen, AK

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1 Steel. You mentioned that you were setting the 2 efficiency levels you established based upon 3 availability of supply. What grades of steel are 4 you considering are available in supply? Let’s just 5 say in design lines 11 and 12. Are you trying to 6 provide availability of H-0s and H-1s? Of M3s? 7 M2s? M4s? What is the supply basis that you 8 believe to be available.

9 MR. CASKEY: Wes can answer. 10 MR. PATTERSON: Wes Patterson, ABB. Eric, 11 what we would see is predominantly M4 and H-0 and H- 12 1, and some M3. As Ray noted, challenge with M3 is 13 the thickness of the steel, right? And the thinner 14 you make the steel, the more labor you put into it. 15 But from capabilities, we could use M3, we could use 16 M2. We’ll definitely end up with M4. You will 17 definitely end up with the laser scribe products. 18 MR. PETERSEN: If I can just respond, 19 then. AK Steel is in a unique position here within 20 -- as we start talking about the M4s versus the H-0s 21 and H-1s, that representing the steel industry, we 22 certainly agree with efficiency levels that allow 23 for M4. And I think some of the challenges is we’re 24 really outrunning the headlights, so to speak, of 25 the DOE data, struggling to understand whether or

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1 not what the DOE’s got is really representative of 2 what the transformer manufacturers really provide. 3 So we’re going to have to lean largely upon what the 4 transformer manufacturers are stating is available. 5 But we are fully in support of a efficiency level 6 that would result in M4 being available as that is 7 something that there would be a -- plenty of supply 8 for the transformer manufacturers, it’s in their

9 best interest. My concern would certainly be, 10 though, that if the efficiency levels that are 11 provided result in the use of H-0 type products, AK 12 Steel is the only domestic supplier within the 13 states associated with a high V (ph) products, so 14 our concern would be that if you’re pushing 15 efficiency levels that place us as the only 16 supplier, you’re essentially giving us -- I don’t 17 want to call it a monopoly position, but you’re 18 essentially giving us the point of supply, and I 19 would challenge transformer manufacturers that 20 that’s the best interest of the industry. 21 MR. PARKER: So you object to this? 22 MR. PETERSEN: What I’m saying is 23 unfortunately I can’t tell -- you know, I’m 24 dependent upon the transformer manufacturers here 25 associated with what they can do. If they’re

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1 confident that this gives them an M4 in both DL 2 scenarios, I’m comfortable with it. If, however, it 3 puts them just at H-0 and H-1, my concern is, I’m 4 your only supplier, and I just question whether 5 that’s the best interest for the industry. 6 MR. PATTERSON: Wes Patterson. Eric, the 7 -- I presented or distributed a presentation showing 8 the core steel grade distributions that are

9 currently used at different energy efficiency levels 10 and this standard was set at those levels. 11 MR. PARKER: Wes, could you speak right 12 into the mic? Please. 13 MR. PATTERSON: And the presentation I 14 gave at this EL-3 level, shows that the dominant 15 steel today is M4, and we do use some laser-scribed 16 in that production space. But from an engineering, 17 technical perspective, I can flip-flop back and 18 forth between the laser-scribe and the M4, and it is 19 solely driven by the relevant price of the two 20 materials. So M4 will stay as an option to be used, 21 as long as its price is competitive with laser- 22 scribe. If that price differential shifts, then for 23 sure we will move all our production over to laser. 24 MR. PETERSEN: Can you comment on design 25 line 11?

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1 MR. PATTERSON: Same. 2 MR. PETERSEN: Same look? 3 MR. PATTERSON: Yes. 4 MR. PETERSEN: Okay. 5 MR. PATTERSON: The only difference 6 between 11 and 12 is the KVA rating. 7 MR. PETERSEN: Okay. So, again, Eric 8 Petersen, AK Steel. Since this is a unified

9 transformer manufacturer’s position, and if all of 10 them are in agreement here, that M4 is a product 11 that will be dominant, that satisfies my concern 12 that they’re not moving to a situation that I’m the 13 only supplier of it, and in my opinion it would make 14 good sense and I would support it. 15 MR. SMITH: Bob Smith, Federal Pacific. 16 What thing to remember about the dry type 17 transformers is that for the most part, we are not 18 going into a market that is evaluating core losses 19 and load losses. So the need for very low loss core 20 steel is going to be much less for the medium 21 voltage dries than it will be for the medium voltage 22 liquids. And I think that’s one of the reasons that 23 you’ll find that the M4 will be more predominantly 24 used. 25 MR. PARKER: Rob?

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1 MR. GREESON: Rob Greeson, Federal 2 Pacific. I issued, and it’s on the record, I issued 3 on Sharepoint, what my estimates were, the breakdown 4 would be. They didn’t totally match up with what 5 Wes came out, I just want to be clear as far as my 6 information is, we don’t have the level of 7 experience that ABB does at the higher grades of 8 steel. I give a lot of weight to what he’s saying.

9 When you look at my numbers, you have to understand 10 we haven’t had as much experience because, you know, 11 you can just ask me, without talking to Wes, and 12 with the level of experience we’ve got, I would have 13 said we would probably use some M4, and maybe shift 14 it a little more towards the M3. Wes is very 15 adamant, tells me hey, you can do it with M4 and had 16 some discussions, did this little presentation, and 17 it was really -- this wasn’t an easy thing for me to 18 come up with, I had to kind of make a lot of 19 estimations, so I guess what the bottom line is, I 20 believe that you can probably do it with M4, I just 21 haven’t -- the paper that I submitted may not say 22 that, but I believe that given what Wes has said, 23 some discussions I’ve had since, that there will be 24 competing core steels. 25 But my initial analysis kind of looked

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1 like it was leaning towards the M3. M3 is a more 2 efficient steel and you can leverage it a little bit 3 better, but it’s awfully -- with the market swings 4 and how things work in the market with price, so 5 there’s a lot of variables. 6 MR. PATTERSON: This is Wes again. One 7 more comment on this. I do have the -- Mike’s 8 position that I buy steel from both of our CGO

9 suppliers, and they both know exactly what my 10 purchase records are. And they also know exactly 11 what factories they go into. So internally they can 12 check the records. The only thing they don’t know 13 is the volume of my production that meets the 14 efficiency level, and the volume of my yearly 15 production that meets an EL-3 is roughly 20 percent. 16 MR. GREESON: Rob Greeson, Federal 17 Pacific. Even if I decided to buy only M3, he still 18 buys a lot of M4. He buys a lot more than I could. 19 MR. POLINSKI: Ray Polinski, ATI 20 Allegheny. And again, just as I’ve been consistent 21 on the liquid filled as well as from this 22 standpoint, I just feel it’s consistent with the DOE 23 practices and the process that the data that I -- 24 that is validated, that I think the DOE has to make 25 their decision based on, it’s the Navigant and DOE

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1 data, and so I just present the crossover points on 2 the data -- that has been at EL-1 for M4. Now if 3 there -- some work needs to be done, and I don’t 4 want to -- I’d love to have data that support -- 5 that’s more consistent with Wes’ data that I could 6 then, you know, say to my management team, hey, this 7 is the data, M4 is in the game, and yes, I can agree 8 to this level. But, you know, without that -- so I

9 don‘t know -- I don’t want to delay the process, but 10 if we can get some more clarity from -- on the data, 11 then some of the plots change according, other than 12 that, I have to be -- because I am consistent with 13 the liquid filled, I have to vote based on the 14 Navigant, LBL data. 15 MR. PARKER: Okay. Thank you, Ray. 16 Andrew. 17 MR. DeLASKI: Ray, I appreciate that 18 comment and I appreciate your striving for 19 consistency. I -- let me just say that what we 20 agree to in this conversation does not commit you to 21 anything else, in my view. I’m not going to say, 22 Ray, over there you said okay because -- and what 23 you said here somehow ties your hands in liquid 24 immersed. I wouldn’t hold you to that, what you’re 25 holding yourself to. Each discussion is an

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1 independent discussion. I know it affects your 2 business. Each of them affects your business, but I 3 think we should have come to … here, independent, 4 not for a -- create some decisionables -- some 5 decisionable by year, somehow has to be applied in 6 either low voltage, low voltage dry or liquid 7 immersed. I just want to be careful that we don’t - 8 - if we do that kind of thinking, I’m afraid we’re

9 going to tie ourselves up in knots and really 10 prevent ourselves from getting to yes. 11 MR. POLINSKI: Ray Polinski, ATI 12 Allegheny. Thanks, Andrew, for the comments. And 13 my only -- my point is that I thought, you know, 14 from my viewpoint, my opinion, is that all the back 15 and forth, and all the files and e-mails and then 16 trees we’ve killed with all the paper on this 17 project, is that the -- it’s been good. The 18 Navigant model and the industry model has gotten 19 close enough together that everyone said, you know, 20 for all practical purposes, the conclusions were 21 very similar. And we just haven’t -- I don’t 22 believe we’ve done anything to tweak the dry type 23 model, and so that’s my problem, is that we’re just, 24 you know, just a little bit like … where you have 25 these two data sets that are wildly different

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1 conclusions or whatever, and I’m just having a hard 2 time deciding which one to take as gospel. So 3 that’s where I’m kind of stuck. 4 MR. PARKER: Andrew. 5 MR. DeLASKI: And I guess I think, Ray, 6 the difference -- a bit of difference, I think, in 7 this situation is that here you have the 8 manufacturers making a proposal as a whole, and that

9 puts us in a little different spot than we are with 10 the other discussion. I think the market data, in 11 this case I think we have market data that is 12 inconsistent with the Navigant data, and that we can 13 use -- I suspect that with additional conversations 14 that Mike’s data will change. I think running out 15 of time is our problem, so -- for negotiated 16 outcomes. So there could be contested outcomes and, 17 you know, that’s another -- then they’ll go where 18 they’re going to go in contested outcomes. But I 19 think it’s sort of a paralysis by analysis risk that 20 we face, and that the market data speaks loudly. 21 We should consider both as opposed to 22 saying the Bible or the iron-clad rule of Mike’s 23 plots. Because I think if we retire some of Mike’s 24 plots … we’ve got to be careful about that. 25 MR. PARKER: So, Andrew, did you want to

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1 respond now to the NEMA proposal or should we take a 2 break -- 3 MR. CASKEY: Can we let Vijay, as another 4 manufacturer -- 5 MR. PARKER: Yes, absolutely. Vijay, I 6 didn’t see your hand, I’m sorry. Go ahead, please. 7 MR. TENDULKAR: This is Vijay Tendulkar 8 from Onyx Power. We make two medium voltage

9 transformers, we’re not a big manufacturer. And the 10 problem is all these materials we’re trying to use, 11 M4 and laser material, if you wanted to use the 12 whole variety of those materials, you have to have 13 fully mitered construction. And as a small 14 manufacturer we’d have to put out a lot of money to 15 get that … and to get the efficiency requirements. 16 The second part is that there are 17 manufacturers around here that are really qualified 18 and sophisticated in their attempts to make use of 19 the various materials and other things. We tried to 20 use it and we had problems. And none of these 21 transformers, we have found out, that they have 22 tested very well when at room temperature, but at 23 the high temperature the core losses went up. That 24 is not expressed in any data in any of this 25 discussions here. The core losses went up 25

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1 percent. That is really a … of the transformer. At 2 room temperature, the core losses are correct, what 3 we calculated. I don’t know if anybody tested this, 4 and I don’t know how we small manufacturers can get 5 all this technology immediately to meet the new 6 efficiency requirements. 7 PARTICIPANT: (on phone) Can you get a 8 little closer to the mic, I can’t hear a thing.

9 MR. PARKER: Okay. Let’s ask everybody to 10 wait until you have the mic in your hands and hold 11 it up to your mouth so … and speak your piece. 12 Okay, John. 13 MR. CASKEY: John Caskey, NEMA. Can we 14 get a clarification on technology relative to this 15 work. As I understand this, the mic is amplified in 16 the room, but it’s not translated to the 17 speakerphone, is that correct, and that these little 18 things on the table are what’s connected to the 19 speakerphone? 20 MR. HYLAND: Let me explain. This is Mike 21 at APPA. The little microphones that are on the 22 table are for her, and her alone, for the record. 23 This microphone, this star contraption, there with 24 those two coming off of it, are the phone that 25 they’re listening to on line. The microphone is

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1 only for internal and is not tied to anything. 2 MR. CASKEY: Okay. So when we have sort 3 of speakers, if you will, we need them to get close 4 to one of these devices in order for them to pick it 5 up. 6 MR. HYLAND: Yes. 7 MR. CASKEY: Okay. So I don’t -- 8 MR. HYLAND: Every time they use the

9 microphone, it should be loud enough to pick it up, 10 if they speak loud, like I do. 11 MR. CASKEY: I’m loudly without the 12 microphone. 13 MR. DeLASKI: So this is Andrew. We -- 14 there’s a significant amount of work put into this. 15 We made our proposal at our phone call, I guess two 16 weeks ago, before Thanksgiving, and for design line 17 11 and design line 12. The NEMA proposal matches 18 our proposal for those two design lines, so we think 19 that -- we really appreciate that NEMA matches our 20 proposal. Those two design lines represent, as we 21 understand from the DOE data, something on the order 22 of 60 percent of sales -- that’s from the DOE data. 23 So it is a majority of data with regard to sales. 24 So we have agreement with NEMA on those categories. 25 The other categories, we don’t have a DOE

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1 analysis that has been completed -- or a completed 2 LCC analysis, but what I understand from the 3 description that was presented to us by NEMA and the 4 manufacturers is that they’ve done the analysis, 5 they’ve done the translation to these other 6 technologies. For example, for design line 13, 7 which is the next largest category, by far, design 8 line 13 being approximately, oh, call it 30 percent

9 of the market, they’re proposing a break, the ten 10 percent more losses than design line 12. So 11 something of a break, of a lower standard that 12 proposed for the same transformers -- same size 13 transformers covered by design line 12. And I might 14 corroborate that engineering difference. So based 15 on that, we’re comfortable with the NEMA proposal as 16 it has been made. 17 MR. PARKER: Thank you, Andrew. If I can 18 just clarify one thing. Design lines 11 and 12 19 currently are both grouped under equipment class 20 eight, and the proposal is two different ELs for 21 those. I take it that one way to get there on your 22 proposal would be just to propose creating a 23 separate equipment class for 11 and 12? 24 MR. DeLASKI: No, I don’t think we need a 25 new equipment class because there’s a whole range of

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1 KVAs, so you have to scale -- you have to scale from 2 the design line across the range of KVAs. Keep the 3 equipment classes the same. I think what we would 4 do with this, we’d have to do the absolute values, a 5 table of KVAs for something that we look to, the 6 consultants could develop in its recommendation. 7 DOE and their consultants have a table based on 8 these decisions, these recommendations. We all have

9 to view it and make sure it makes sense. 10 MR. PATEL: This is Dhiru Patel from 11 Hammond. May I comment? 12 MR. PARKER: Excuse me, Andrew, were you 13 finished? 14 MR. DeLASKI: Yeah. 15 MR. PATEL: Hello? 16 MR. PARKER: Yes, go ahead please. 17 MR. PATEL: This is Dhiru Patel from 18 Hammond Power Solutions. Regarding the scaling, we 19 at Hammond, we did … designs for the design line 20 that is given by -- as a proposal. And then we 21 started looking at these smaller ratings because 22 smaller things are typically the bore issues, so on 23 the design line … KVA and 95 KVA and we checked that 24 and then … to 225, 75, and smaller to 15 for 95 25 KVA. And we do the scaling that … efficiency and we

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1 tried to … KVA and smaller, we are finding very, 2 very difficult to improve on the level that the 3 current DOE regulations. And the reason being, … 4 smaller, the core becomes smaller but the clearance 5 to the core and the … fan, because it is … by the 6 BIL level and the voltage drop of the winding. 7 So what happens is on the smaller units, 8 the core is much larger proportioned than the coils,

9 and you have to achieve that efficiency by 10 incrementing the core. Now you have a small core, 11 the … also is smaller and there’s a higher effect on 12 the … KVA. And that also will help in the 13 improvement in the efficiency. So until the scaling 14 factor is known, that what kind of efficiency will 15 be proposed for smaller KVA, it is very difficult to 16 even comment. Because I know from 15 to 35 KVA, the 17 slightest improvement on the current level is almost 18 impossible with the steel going from M6 to M3 … 19 We considered the … etched, but with a 20 very small space, it’s very, very difficult. Any 21 comments from anybody else? 22 MR. PARKER: Okay. Vijay, if you can come 23 and stand next to the star mic so people on the 24 phone maybe can hear you? Speak into that mic. 25 MR. TENDULKAR: This is Vijay Tendulkar,

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1 Onyx Power. I looked at our numbers, we are going 2 to reduce our losses by 35 percent, and we have done 3 some calculations in our company, and I don’t think 4 we can make any of those losses by 35 percent lower 5 than that. Maybe we can go somewhere around 15 6 percent or something improvement, but not 30 7 percent. Thirty percent will be impossible for us 8 with our current technology and the equipments we

9 have, we’d be very hard pressed to do that. I don’t 10 think we will meet it. We’ll have to get out of 11 this distribution transformer market completely. 12 MR. RIVEST: Mike Rivest, Navigant. Just 13 to clarify. Are you -- 14 MR. PATEL: I can’t hear -- much louder. 15 MR. RIVEST: This is Mike Rivest. 16 Clarifying question. Are you in all segments of 17 this market, or are you only in some of the 18 representative units. 19 MR. TENDULKAR: Medium voltage dry types. 20 MR. RIVEST: Are you in all BIL and all 21 KVA ranges as well? 22 MR. TENDULKAR: Up to 95 KVA BIL, about 25 23 KVA. 24 MR. RIVEST: So -- okay. 25 MR. PARKER: And this is not your data

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1 set, these are all -- 2 MR. TENDULKAR: These are separate 3 distribution transformers. 4 MR. PARKER: Steve, did you -- 5 MR. ROSENSTOCK: Are you taking more 6 comments or -- 7 MR. PARKER: Yes. 8 MR. ROSENSTOCK: Who was first?

9 MR. GREESON: Rob Greeson, Federal Pacific 10 Transformer. 11 MR. PARKER: Rob, can you come over here 12 again to the mic. 13 MR. GREESON: From Hammond’s discussion of 14 scaling factor, I’ve run into the same issue. I 15 haven’t looked at it in quite the detail it sounds 16 like he did, but from the work that I did, when you 17 get into those smaller KVAs, you do have those 18 problems. It’s harder to meet those efficiencies. 19 There may very well be a problem on the lower end 20 KVAs. The work that I did, I concentrated on the 21 300 and the 1500, but you know, you’ve got a lot of 22 KVA sizes that are covered below 300 KVA. I don’t 23 think it’s unreasonable to expect that maybe the 24 scaling factor is somewhat higher than what your 25 efficiencies -- they might be tapered down a little

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1 bit on those lower KVAs. But from the advocates’ 2 standpoint, I don’t think the MVA shipments from 3 those lower KVAs are an issue. In the last meeting, 4 I think we even talked about making -- leaving some 5 of those KVAs alone. 6 MR. PARKER: Do we have any data on what 7 the shipments are for the 15 to 30 KVAs? 8 MR. GREESON: There might be -- I think

9 that might be an issue. He’s right about the 10 construction factor and the proportionality of the 11 core, of the losses to the overall losses. It 12 increases and because -- it’s the nature of the 13 design. 14 MR. DeLASKI: This is Andrew. I, again, 15 our focus is on energy savings. And my 16 recollection, as Rob points out, that we have had 17 this conversation in earlier meetings. The extent 18 of that conversation, we’ve been around this, and we 19 agree that -- I think, Mike, from talking to you and 20 talking to Wes, how do you scale down, and that 21 there are these edge effects, or call them … effects 22 of some sort, that you can’t use this scale. So I 23 guess we look to you, to work with you guys, to 24 figure out how to do that scaling, and come back 25 with the table and then react to that. In

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1 principle, we’re agreeing that you have to -- there 2 would be some need to address the smallest -- the 3 smallest products -- not with the same factor, 4 right. 5 MR. GREESON: I think we agree, then. 6 MR. DeLASKI: Yes, I think we agree. 7 MR. PARKER: Steve Rosenstock. 8 MR. ROSENSTOCK: Steve Rosenstock. I

9 appreciate the presentations and I’m looking at the 10 analysis that’s stated in November 28, 2011, the 11 most recent analysis for the medium voltage dry type 12 transformers. I’m looking at slide five, design 13 line 11, LCC default results, which is all the 14 materials, all metals. At level two, what I’m 15 seeing here is a 58.75 percent of … net increase in 16 life cycle cost, 41 percent -- 41.25 percent on the 17 savings of LCC, and mean and median LCC savings for 18 EL-2 at design line 11, default results, …. That’s 19 slide five. That’s the slide. That’s correct. 20 So, looking at the economic justification, 21 I do have some concerns with that one. 22 Looking at design line 12 on the next 23 slide, the -- in terms of LCC savings for design 24 lines one and two both have 90 percent of 25 transformers have net LCC savings. Design line two

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1 has higher mean LCC savings than design line three 2 median savings. 3 Then when I scroll down to the payback 4 numbers on slide seven, design line 11, I’m looking 5 at the payback periods and for design line two, a 6 mean payback period of 26.9 years, median of 20.2 7 years. Much higher than what’s with EL-1. And then 8 on design line 12, 15 years for design line three,

9 nine years for two, six years for one. And then of 10 course you have the median and the average ones as 11 well. 12 So I appreciate -- and then there’s a 13 metals and transformer -- so I like the fact that 14 the parties are coming together, but I’m worried 15 about some of the economic impacts of some of the 16 these levels. So I don’t know if we’re going to do 17 a series of straw votes. I would not mind seeing -- 18 at least allowing us to vote on levels one, and two 19 for design line 11, and one, two, and three for 20 design line 12. I’m not making any comments on 21 nine, ten, and 13. 22 We do have some economic analysis for 23 nine, ten, and 13 -- I remember. I do have that 24 presentation -- don’t use that any more? Okay. I’m 25 sorry. But there must have been some printed

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1 analysis, so I’m just using November 28th, so I just 2 wanted to, just from the analysis that was 3 published, just wanted to point some of those out 4 for people. Thank you very much. 5 MR. PARKER: Okay. A couple more brief 6 comments, then I do think we should break for a few 7 minutes to let people talk. 8 MR. POLINSKI: Ray Polinski, ATI

9 Allegheny. Andrew, you had mentioned previously, 10 though, in a comment that consistency amongst what 11 we do for this one -- this dry type medium voltage 12 maybe doesn’t apply to the dry -- I mean the medium 13 voltage liquid filled. And so, anyhow, just from a 14 consistency standpoint, I hear what you’re saying. 15 You’re saying, hey, the manufacturers, the 16 transformer producers, you know, they’re making a 17 recommendation and they don’t want to put themselves 18 into a non-competitive situation when it comes to M4 19 and core steel and things of that nature. And I hear 20 some other comments. 21 So I’m kind of -- I kind of initially had 22 said that an EL-1 across the board. And so 23 consistent with that movement in that direction, I 24 think I could probably move to an EL one and a half, 25 still not to where the group is, and -- but a little

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1 bit on the same vein though, I would ask that you, 2 and your group, would listen to the manufacturers on 3 the liquid filled medium voltage as well. I mean, 4 they’ve spoken, and you -- you’re asking me to put a 5 lot of weight on what they’re saying. I’m asking 6 you and your group to put some weight on their 7 recommendations on the medium voltage liquid filled 8 as well. Thank you.

9 MR. PARKER: Andrew. 10 MR. DeLASKI: I’m going to talk liquid 11 filled off line with you, Ray. Let’s have this 12 conversation off line. For this one, yeah, Steve, 13 we noticed some of the same changes to the LCC that 14 -- the latest. So, we’re a little puzzled by them, 15 frankly, because what happened relative to the last 16 analysis that we used as the basis for our 17 conversation on the phone call, is that the LCC got 18 worse for design line 11, and it got better for 19 design line 12. So they moved in opposite 20 directions based on using the 2011 steel prices 21 instead of using the 2010 steel prices. So here we 22 are back to steel prices again. 23 And as I understand it, what’s primarily 24 driving it is base case, because steel prices went 25 down to base case by 30 percent of their … And you

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1 just have a different shape to the curve. So this 2 is the 2011 data. The 2010 data is what we based 3 our recommendation on last time. We didn’t have the 4 benefit of this data at the time. I suspect, you 5 know, from some of the comments made by the 6 Department or the consultants earlier, that in the 7 final analysis some sort of averaging of these 8 prices is going to be necessary and you’re going to

9 end up with results that are not what we’re looking 10 at right here. But it is the proposal. We have the 11 LCC -- it makes it hard to convert, so -- yes, 12 doesn’t it. 13 So again, we based our recommendation on 14 the last LCC 2010 prices. If you do an averaging, 15 you’re going to come out -- a five year moving 16 average, I don’t know if that’s a right number or 17 not, but you’re going to come up with something. 18 That was what we used in 2007. Even another result, 19 I’m comfortable with the manufacturers’ proposal in 20 this case. 21 MR. PARKER: We also have to remember that 22 we’re comparing apples and oranges in the LCC. 23 We’re comparing a computer model and an optimization 24 model done by analysts who are outside the industry 25 to results that we have --

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1 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 2 appreciate that. Again, I was looking at this 3 because I heard yesterday, I hope I’m not mistaken, 4 that DOE wanted to use 2011 data for their decision- 5 making. 6 MR. DeLASKI: Yeah, and -- 7 MR. ROSENSTOCK: That’s what I heard, 8 that’s why I’m looking at this -- this one here

9 today. That’s why. 10 MR. PARKER: Let’s take a short break and 11 reconvene in 15 or 20 minutes. 12 (Whereupon, at 11:10 a.m., the meeting was 13 off the record for a 32 minute period, until 11:42 14 a.m.) 15 MR. PARKER: So we have 45 minutes before 16 our scheduled break at 12:30. At 12:30 we will 17 adjourn, approximately, and those that are coming 18 back for the low voltage talks will have an hour and 19 a half for lunch -- the low voltage talks at two, 20 here. 21 On medium voltage, I think we’ve had a 22 very, very positive and very constructive 23 discussion. I appreciate the hard work on 24 everybody’s part that has joined in this. We have 25 proposals on the table. We have discussed them.

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1 What I’d like to do now is basically direct a straw 2 poll on each of the proposals that have been put 3 forward. 4 Let’s see just where -- again, this is not 5 a permanent thing. This is not the final -- the 6 final say. This is just -- 7 MR. ROSENFELD: Richard, this is Art 8 Rosenfeld. I simply can’t hear you.

9 MR. PARKER: Oh, sorry. This is not the - 10 - this is not intended as the final word on this. 11 I’ve heard from stakeholders around the table that 12 there are still are some concerns about the current 13 DOE analysis, and there is a sense, I think, on all 14 sides, that the DOE analysis can be refined, based 15 upon input from people here, to come into more align 16 with what we’re hearing from the source of that 17 analysis anyway, which is the transformer 18 manufacturers and steel people about what is 19 possible. 20 I also want to emphasize that the 2011 LCC 21 results that you’ve got were not optimized designs, 22 and they were done by an optimization process -- 23 excuse me -- a selection process by consultants who 24 are not in the actual industry themselves, so I 25 think wherever there is a conflict between a theory

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1 and the reality, the reality should prevail. The 2 question is, can we come up with an analysis that 3 reflects that, and I feel pretty confident that we 4 can. 5 At the same time, I know that people came 6 with a certain understanding, certain instructions 7 from their management, and they need to go back to 8 their management and get further authorization

9 before they can move from that. 10 Final Discussion and Straw Poll

11 So, with that in mind, what I’d like to do 12 is starting off with the NEMA proposal, let’s have a 13 show of hands for that. If we could, before we 14 vote, if John Caskey could just in a nutshell, 15 review the proposal one last time so it’s up in 16 everybody’s mind, we will hear that and then we will 17 conduct our straw poll. 18 MR. CASKEY: Okay. This is John Caskey, 19 NEMA. I think what I’ve got here is: 20 • For design line 9, we’re recommending EL 1.5 21 • For design line 10, EL 2.0 22 • For design line 11, 2.0 23 • For design line 12, 3.0 24 • For design line 13, we’re going to work and try 25 and resolve that issue, but for the higher

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1 BILs, we want basically ten percent more losses 2 allowed than under the DL-12. We’re not sure 3 how that relates to an EL level yet. We need 4 to work on that. 5 MR. PARKER: When you say “higher BILs” do 6 you have a -- 7 MR. CASKEY: Above 95. 8 MR. PARKER: Above 95. Thank you.

9 MR. CASKEY: So the things that we still 10 need to work on is what I just said about the higher 11 BILs, the single-phase issue that is not a direct 12 calculation from -- or a simple normalization from 13 three-phase to a single-phase. We need to provide 14 for the fact that it is more difficult to produce 15 one than the other. And the third area that -- I 16 think everybody agreed to work on that -- and the 17 third area deals with the smaller KVAs, and 18 particularly in the 15 -- below 300 KVA and look at 19 trying to make sure that we adjust for that because 20 the manufacturers reported that it’s -- in some 21 areas it’s more difficult to go beyond the EL-1. So 22 those are the -- 23 MR. PARKER: Below 300 KVA is the 24 threshold? 25 MR. CASKEY: Yes.

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1 MR. PARKER: Okay. Any other clarifying 2 question before we go on and vote? 3 MR. ROSENSTOCK: Quick process? Steve 4 Rosenstock, EEI. Are we going to vote on all the 5 design lines as one package, is that the idea, or 6 separate design lines? 7 MR. PARKER: Why don’t we vote on them as 8 a package, I think that would be much simpler, thank

9 you. All in favor? (Counting.) Twelve. Opposed? 10 (Counting) Seven. Abstain? One. 11 MR. CYMBALSKY: Two. I’ll abstain for 12 Art. 13 MR. PARKER: Okay. Two abstain. So, 14 seven no’s, twelve in favor, two abstain. Okay. So 15 I think what we should do, both for medium voltage 16 and for liquid immersed is move forward. 17 MR. ROSENSTOCK: Can we take another straw 18 vote here? 19 MR. PARKER: What’s that? 20 MR. ROSENSTOCK: Can we take other votes 21 here? 22 PARTICIPANT: Two more proposals. 23 MR. PARKER: Yes, sorry, sorry, sorry. 24 Yes. Please. Steve, do you have any proposals. 25 MR. ROSENSTOCK: Well, I -- Steve

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1 Rosenstock, EEI. There are two proposals. One for 2 EL-1 across the board, and then EL-1.5 across the 3 board. That’s what I heard earlier. 4 MR. PARKER: Okay. Ray, would you like to 5 state your proposal? 6 MR. POLINSKI: Ray Polinski, ATI 7 Allegheny. And as I said, for now I’d just like to 8 vote on the first proposal that I went out there,

9 which was EL-1 across the board for design lines 10 nine through 13. 11 MR. PARKER: Okay. Thank you. Since we 12 only had two proposals, I had sort of assumed that 13 the results of holding a straw poll on the second 14 would be the inverse of the first, but I’m perfectly 15 happy to go through the exercise. 16 MR. PARKER: Okay, Steve? 17 MR. ROSENSTOCK: I’d like to take a straw 18 vote on EL-1.5 across the board. 19 MR. PARKER: All in favor? 20 PARTICIPANTS: One point five. 21 MR. PARKER: One point five across the 22 board. All in favor? (Counting.) Seven. Okay. 23 All opposed? Vijay, you’re not on the committee 24 still. (Counting.) Seven. Abstains? (Counting.) 25 Eight. Eight, I keep forgetting Art.

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1 Thank you. Any other proposals? Okay. 2 One of the shortcomings of straw polls is that, or 3 any kind of polls, or any kind of polling process is 4 that they don’t register an intensity of preference, 5 and I do get a sense that there is a lot more 6 flexibility around the table in the medium voltage 7 dry than in the liquid immersed. But I also get a 8 sense that there’s still some flexibility in the

9 liquid on the decision that we had last night after 10 the meeting -- 11 (Discussions off mic) 12 Proposal for Next Step

13 MR. PARKER: So, what I would propose is 14 that moving forward first we recognize that we are 15 out of time in terms of meetings. We have spent a 16 great deal of time getting the analysis to date, and 17 defined, and getting to understand it better, and 18 that process continues. I think we can actually 19 enter the phase where plenary meetings are less 20 useful than smaller group meetings, caucuses, that 21 we can do by telephone conference calls, and over 22 the next few weeks, hopefully couple of weeks, as 23 people talk to each other and reflect on their 24 positions and the data continues to emerge and 25 evolve, and the analysis evolves, I am hopeful that

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1 we can bridge some of the differences, both in 2 liquid immersed and medium voltage that we’ve 3 encountered so far. 4 And so I think that that might be a useful 5 way to proceed. We have had a good experience so 6 far in this group with telephone conference calls in 7 both the medium voltage and low voltage space -- 8 calls -- those were productive calls. I suggest we

9 move forward if we don’t have meeting space reserved 10 that we can be physically present. So that’s what I 11 would propose to do. If you all -- I think we need 12 to -- we’re all curious about, you know, where DOE 13 is in this process and , you know, I think we’re 14 going to need to explore what -- where people -- 15 where stakeholders are, including the Department at 16 this stage, in a … way, an exploratory way, and hear 17 from everybody about what they can give, what they 18 can’t give, and what progress we can make, if any. 19 So, I would propose that we move forward 20 in that way in the next couple of weeks, and then 21 take stock of where we are. Eric. 22 MR. PETERSEN: Eric Petersen, AK Steel. I 23 don’t know if you want me to say this or not, 24 Richard, I’ll just throw it out. But we have had a 25 change in our position at AK Steel as to how we

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1 voted yesterday, would you like me to bring that to 2 the table, or you just want to deal with it on the 3 individual basis, considering where everything is 4 at. Obviously, one vote wouldn’t make a change in 5 consensus, but -- if you’d like me to speak to it, I 6 can tell you how our vote would change from 7 yesterday. 8 MR. PARKER: That would be very helpful.

9 Go ahead. 10 MR. PETERSEN: Okay. Yesterday, we voted 11 that -- 12 MR. ROSENFELD: Richard, one point -- this 13 is Art Rosenfeld. I just understood my phone was on 14 mute and I abstained on all three votes, and 15 particularly since nobody could hear me, but just 16 for the record, I abstained. 17 MR. PARKER: Thank you, Art. I think John 18 anticipated your position and entered your position 19 on your behalf. 20 MR. ROSENFELD: Thank you. Sorry I messed 21 up. I’ll shut up again. 22 MR. PARKER: Talk whenever you feel like 23 it, Art. You’re most welcomed. Go ahead. 24 MR. PETERSEN: Eric Petersen, AK Steel. 25 I’d like to comment that as we had some discussion

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1 last night in regards to our position and how we 2 voted yesterday. If we were to vote again today, we 3 would change our position, versus on how we voted 4 yesterday, and I think the key that we see is we are 5 interested in identifying an efficiency level at 6 which grain-oriented electrical steel has an 7 opportunity to compete against amorphous metal, and 8 that there is plenty of opportunity for supply for

9 the transformer manufacturers. That’s the key point 10 that we are looking for. 11 In trying to find exactly how far we can 12 go, we are very confident that there absolutely is a 13 cliff that you could result into a essentially 14 monopoly position of amorphous metal. So our 15 concern is understanding how far you can go until 16 you hit that cliff. Our modeling capability cannot 17 get us there, so we are going to be dependent upon 18 those people that are the experts, that being the 19 transformer manufacturers. The transformer 20 manufacturers, as we communicate with them, have 21 communicated to me that they are interested in that 22 same goal, in providing a business model that 23 insures that they have a competitive supply base 24 which insures that steel has an opportunity to 25 produce.

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1 While we recognize that the DOE/Navigant 2 modeling has some issues, this model of liquid 3 immersed is certainly better than what we just 4 talked about because of the efforts that have been 5 made on the transformer manufacturers part. I want 6 to thank the transformer manufacturers for spending 7 that amount of time. So, in our perspective in 8 trying to understand where we can go, we’re going to

9 depend upon our customers, the ones that are the 10 experts, the transformer manufacturers are the ones 11 that can define, amidst all this modeling, all these 12 technical issues, where they can build a transformer 13 that insures that there is a good supply amongst the 14 product base. 15 So with that in mind, we would change our 16 vote from what we provided yesterday to move to the 17 NEMA vote, which was the one, zero, one, one, one, 18 recognizing that again, as I stated, they’re the 19 experts, and I think it also provides us an 20 opportunity to improve. It’s not a step backwards. 21 It is a step forward, and also puts a -- what I 22 call, mitigated safeguard in regards to this 23 refurbishment issue. 24 It’s been commented numerous times. I 25 think it has been justified as a question. I agree

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1 that it has not been justified as an actual reality 2 of where it’s going to go, but it certainly a 3 question, and moving to the NEMA level will allow an 4 opportunity to increase, provide a stable supply, 5 and not go so far that you have to be concerned 6 whether or not you’re going to, for lack of a better 7 analogy, release the lion and then determine are you 8 going to go find the gun or some way of dealing with

9 it. 10 We have not been able to define that there 11 is a clear methodology of dealing with a means of 12 regulating a refurbishment industry. Without that 13 in place, recognizing the significant diminishment 14 it could handle, I would strongly recommend that we 15 take NEMA’s recommendation as it gives time, then, 16 for efforts to be made, of handling a regulatory 17 mechanism by which you can insure that refurbishment 18 does not diminish the efficiency standards and 19 benefits we would gain from a level that is well 20 beyond NEMA’s standard. 21 So that’s the position that we have come 22 to in regards to where we would go. 23 MR. PARKER: Thank you, Eric. Any other 24 comments on this -- any other comments on the straw 25 poll we took yesterday? Okay, does the premise that

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1 I have suggested make sense to the group with regard 2 to the liquid immersed, first? And secondly with 3 regard to medium voltage dry type? Steve. 4 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 5 think what you’re saying does make sense, but if 6 there’s going to be off-line conversations, to use … 7 word, let’s just say we’re shifting to e-mail 8 traffic. I think it would help if, you know,

9 because I think people want to continue the 10 conversation -- if we could get some guidance in 11 terms of when we decide on some numbers, would it be 12 fair to DOE and the analysts if they have to retype 13 all the numbers based on, say, a negotiated number - 14 - what would be a fair deadline to get them, say -- 15 why not just ask for -- okay, if DOE has to publish 16 something by February 1st, what’s our real deadline 17 in terms of -- if you’re going to get numbers here 18 to be fair to the analysts and to DOE in terms of 19 writing up something? In my mind, that would be 20 helpful to all parties. 21 MR. PARKER: Well, that’s a fair question. 22 I think the best way to answer that is to recount a 23 conversation that I had with Phil Harter last night, 24 who I’ve been consulting regularly throughout this 25 process, and who invented the concept of negotiated

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1 rulemaking and has done any number of these in the 2 past, ending up successful. But I said, Phil, we 3 seem to be pretty stuck on liquid immersed. He 4 said, well, how long has it been since you -- since 5 everybody was at the table and took the first straw 6 poll? And I told him, 30 minutes. So we had taken 7 a long time to get where we are, but we have not 8 yet, you know, I think reached a point where

9 reasonable people would say we can’t make any 10 further progress. In fact, I think based upon the 11 discussions of last night and this morning, we are 12 far from that point. So that’s my proposed 13 continuing the dialogue. 14 Now, in terms of timing, February 1st is 15 rapidly approaching. In order for the OMB to get 16 their product reviewed and advanced, they would need 17 something by January 1st at the latest, as I 18 understand. And the question is, what do you do 19 given those time frames? One possibility that I 20 have discussed with Dan Cohen who was on the 21 webinar, is the idea of the Department publishing a 22 NOPR on schedule that would contain all the stuff 23 that a NOPR normally contains, and all of the -- all 24 the elements of the standard one would need, but 25 would contain, basically, brackets for those areas

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1 that we have decided, and that we’re saying we will 2 propose these levels, we’re taking comment on them, 3 but we haven’t taken a firm position. 4 This doesn’t mean that the Department will 5 state informally, off-line, which way they’re 6 leaning. Individuals at the Department won’t, but 7 in terms of the NOPR, it doesn’t have to be a 8 proposed rule. As a professor of administrative

9 law, very familiar with the APA, as is Dan Cohen, 10 we’ve had this discussion. Everyone is comfortable. 11 What the APA calls for is a Notice of Proposed 12 Rulemaking. The idea that you actually fill in a 13 draft rule and file that is a matter of custom. It 14 is not a matter of law. It’s not required. And so 15 the NOPR can be a document which leaves open blanks 16 which this body will fill. 17 Now, that said, there does still need to 18 be a deadline. Because what is not flexible is the 19 October 1 date for a final rule, and there has to be 20 time for public notice and comment before then. So 21 we can have a protracted process, and will have a 22 protracted process if this drags on into the spring. 23 At the same time, we don’t have to be like deer in 24 the headlights with regard to the February 1st 25 deadline.

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1 That’s my understanding from the 2 Department. John, is that acceptable with the DOE 3 perspective? John is saying yes. So this also 4 raises the question from the standpoint of the 5 advocates in the corner of the deadline, so Andrew 6 has his hand in the air, and I will call Andrew to 7 respond to that. 8 MR. DeLASKI: It’s a novel concept.

9 (Laughter.) And I’m not questioning it in terms of 10 law. I know that … has sometimes proposed rules 11 with multiple options, but restricting blanks 12 strikes me as being outside the scope of Department 13 practice in past years. So I’m concerned about this 14 notion of just blanks. Now options -- 15 MR. PARKER: No, no. I’m sorry. I did 16 not mean -- when I said brackets, I didn’t meet to 17 populate those brackets with blanks, I meant to 18 populate them with multiple options, yes. 19 MR. DeLASKI: And I see scaling as well, 20 so I think this is something that we’re going to 21 take under consideration. The Department issues a 22 proposed rule, an opportunity for public comment on 23 that proposed rule. The problem with one, we’re not 24 the whole world at this table. There are other 25 comments or proposals, and there’s a schedule and a

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1 timeframe for that in the process that’s as 2 important as well. So we’ll take it under 3 consideration, but it’s not something we’re prepared 4 to sign off on as a process question, I think, 5 sitting here today. It’s new -- it’s a brand new 6 idea. 7 MR. PARKER: Tim, did you want to comment? 8 MR. BALLO: Sure, the idea of brackets --

9 I guess I don’t see the harm in proposing a standard 10 that reflects the Department’s actual thinking at 11 this point, and then the door is always open to 12 modify that, you know, in the future, based on the 13 comments received. So I don’t see why this NOPR 14 would have to be different from regular practice. 15 Also, at least with regard to the low 16 voltage dries, the APA is not the only criteria that 17 applies. There’s the six year provision in APCA 18 (ph) provides that the Department must issue a 19 Notice of Proposed Rulemaking, including new 20 proposed standards. So I think at least for the low 21 voltage dries, you do have to propose something 22 specific. 23 As far as the court case and -- 24 MR. PARKER: Tim, the low voltage dries is 25 not even subject to the law suit, so --

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1 MR. BALLO: Yeah, but -- anyway. AS far 2 as the February 1st deadline, I think our interest is 3 primarily in getting something out as a proposal, 4 and I don’t see that as a roadblock to any consensus 5 process that would develop, or joint comments that 6 would endorse something that all or most of the 7 parties involved agree on. I don’t think that a 8 proposed rule would foreclose adoption of a final

9 rule reflective of what we could agree on. 10 If others see things differently, I’m 11 ready to discuss the possibility of further 12 extension. I can’t say that I would agree for it.

13 MR. PARKER: I’m not sure that we have to 14 decide here today what the deadline is, or how a 15 February 1st NOPR would be worded. I’m not sure it’s 16 our interest to try to micromanage the future that 17 way. I offered that as an option, as a sort of 18 worst case option, should that become necessary, and 19 should it be deemed desirable. 20 Another option would be for the Department 21 just to issue their NOPR with the brackets filled 22 in. It has the effect of heavily entrenching 23 positions, but it is a notice and it is subject to 24 further comment, and it can be changed. So it 25 doesn’t lock anybody in. So that would be another

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1 option. And I don’t think we necessarily have to, 2 today, choose between those options. 3 The point that I was simply trying to make 4 was that there are a variety of ways that we could 5 handle the February 1st deadline that would allow us 6 to continue our talks beyond today. That was my -- 7 MR. DeLASKI: Just to follow on. I mean 8 the parties to the suit are -- or at least some of

9 the leads to the suit -- the parties to the suit are 10 around the table, so it strikes me that if there is 11 a consensus that emerges between now and hopefully 12 relatively soon, the sooner the better -- but if a 13 consensus emerges, then I think flexibility along 14 the dates could be more likely. So the two things 15 are linked. It isn’t like we’re talking about … the 16 law suit is not … outside this room. So if we’re 17 not making progress, then I think the interest in 18 extending the deadline is -- goes away. We’ve got 19 to keep on for further process. 20 MR. PARKER: And Andrew points to a third 21 option, which is that if we are making progress, and 22 if there is a view that more time would be 23 necessary, that an option would be to go to the 24 court and provide another 30 days or whatever he 25 thinks is appropriate, based on what it is the

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1 process … up there. So we have not one but three 2 different ways of handling -- of answering Steve 3 Rosenstock’s concern. 4 MR. CYMBALSKY: Hi, John Cymbalsky, DOE. 5 I just want to -- what Richard mentioned is an 6 option and no decision on how the NOPR will be 7 written has been made at this time. It’s just an 8 option that’s been used in other agencies. Andrew

9 is correct, we, as far as I know, have never used 10 sort of pure all the TSL levels. We haven’t picked 11 one yet. We haven’t done that before. It’s been 12 done in other agencies, as far as I am aware. No 13 final decision by the Department has been made on 14 how we’re going to write the NOPR at this time. 15 MR. PARKER: Any other comments on that? 16 So is there agreement to keep talking in good faith, 17 and not just talking, but negotiating and moving in 18 a somewhat different format, but hopefully with a 19 clear purpose and still with ex… timeframe? All in 20 favor? Opposed? Well, we’ve reached consensus on 21 one thing. Great. With that, you all deserve 22 lunch. Let’s break at 12:15. 23 For the people who are leaving us today, 24 thank you so much for your involvement in this 25 process, and it’s been a very, very helpful and

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1 productive journey. We still have a ways to go, but 2 I’m hopeful that with good faith and hard work, we 3 can get there. 4 MR. BALLO: Richard, I would just ask, 5 would folks find it helpful to tentatively schedule 6 another call in a couple of weeks to check in on … 7 MR. PARKER: That might be a good idea. 8 I’m not sure that -- I guess my instinct was to sort

9 of let’s caucus and let’s talk to people 10 individually and see how things are going and at 11 what speed. Calls may be set much more easily than 12 me -- 13 MR. BALLO: Around the holidays -- 14 MR. PARKER: That may be true. I’m open 15 to the idea of scheduling a call if people want to 16 do that. You’re talking about a plenary call now, 17 right? For the entire group? Anybody have a 18 calendar with them? 19 (Discussion off mic) 20 MR. PARKER: Great. Let’s see. What 21 about eleven o’clock on the 14th? I’ll just throw a 22 number out at random. 23 MR. ROSENSTOCK: Yes? 24 MR. PARKER: What’s that? 25 MR. ROSENSTOCK: Are you asking for yes

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1 votes for that time period? 2 MR. PARKER: Eleven o’clock on the 14th, 3 yes. All in favor. 4 MR. CASKEY: I can’t -- 5 MR. PARKER: Anybody can’t make that? You 6 cannot make that. John, can you propose an 7 alternative? 8 MR. CYMBALSKY: I’m looking for my --

9 MR. PARKER: No, I’m looking to John 10 Caskey, sorry. He said he couldn’t make it. 11 MR. CASKEY: That’s two weeks from 12 yesterday? 13 MR. PARKER: Right. Again, I think we 14 should approach this with the idea that this is 15 notional, the time, because I think what’s more 16 important is to -- is to stage a plenary call at a 17 time when we really, you know, are at a stage where 18 people may have come together in their minds with 19 small group meetings. So I had some reservations 20 about locking us into a time, but I can see the 21 attraction on the other hand, to try to keep the 22 train moving. 23 PARTICIPANT: A place holder. 24 MR. PARKER: Yeah. John Caskey, did you 25 have a -- is there another time on the 14th or is the

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1 whole day -- 2 MR. CASKEY: The whole day is out. And 3 even for the 15th, I’ve got other like management 4 meetings, but I don’t have the agenda yet to know 5 what time I would need to be in them. 6 MR. PARKER: Okay. 7 MR. CASKEY: But Jim can fill in for me. 8 Jim is my substitute if for some reason I can’t make

9 it. Jim Creevy. 10 MR. DeLASKI: I would suggest to go to the 11 following week, on Monday or Tuesday. 12 MR. PETERSEN: Eric. 13 MR. PETERSEN: I guess my point is we 14 talked about Wednesday through Friday months ago as 15 tentative, and I’ve got those dates available. I 16 guess my recommendation would be to go with those 17 three days as we identified those some time ago. 18 Either one of them, Wednesday, Thursday, or Friday 19 is good by me. 20 MR. DeLASKI: I’m out Thursday, Friday. 21 Not out, I’ve got other commitments. 22 MR. PARKER: What about Wednesday -- I’m 23 sorry my calendar is not on here -- what date is 24 Wednesday? 25 PARTICIPANT: Fourteenth.

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1 MR. CASKEY: I can’t do it. Jim, can you 2 cover for me? 3 MR. PARKER: Okay. So Jim can join us on 4 the 14th, then? Okay. Time. Eleven o’clock goes 5 into the lunch hour and it might go a little more 6 than an hour, shall we say ten o’clock on the 14th? 7 MR. DeLASKI: Yes, west coasters -- so one 8 o’clock? One o’clock on the 14th. 9 MR. DeLASKI: I can’t do that.

10 (General discussion on time.) 11 MR. PARKER: Okay. Eleven to one on the 12 14th. 13 MR. SMITH: Richard, Bob Smith, Federal 14 Pacific. Before we adjourn, may I ask you a 15 question? 16 MR. PARKER: Sure. 17 MR. SMITH: You made an interesting 18 comment a while back, stating that while the votes 19 for the medium voltage dry type were somewhat 20 similar that we saw in the medium voltage liquid 21 meeting, that the intention of the DOE of trying to 22 come together was much closer with the medium 23 voltage dry types. And I am wondering if it would 24 be possible for you or another appropriate person to 25 visit with the people who voted no and ask them

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1 under what conditions would they change their vote 2 to a yes. That those conditions may be better 3 information from Navigant. It may be that M4 has to 4 be a viable steel for all of the efficiency levels, 5 but if you or the appropriate person could do that 6 with those that are voting no, I think that would 7 help us get our issues resolved much quicker. 8 MR. PARKER: Thank you, Bob, that’s why

9 they gave me the small bucks. Yes, I plan to do 10 that. 11 MR. SMITH: That would be great. If you 12 could share with the rest of us that are supporting 13 the NEMA proposal, that would be terrific. 14 MR. PARKER: Thanks, Bob. Anything else 15 before we adjourn? For those leaving us, bon 16 voyage, and thanks. For those rejoining us for low 17 voltage, in the afternoon, we’ll reconvene here at 18 two. Enjoy your lunch. 19 (Whereupon, at 12:18 p.m., the meeting in 20 the above captioned matter was adjourned.) 21 22 23 24 25

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REPORTER'S CERTIFICATE

This is to certify that the attached proceedings before:

U.S. DEPARTMENT OF ENERGY

In the Matter of:

MEETING of the MV WORKING GROUP

Were held as herein appears and that this is the original transcript thereof for the file of the

Department, Commission, Board, Administrative Law

Judge or the Agency.

Further, I am neither counsel for or related to any party to the above proceedings.

Wendy Greene Official Reporter

Dated: December 6, 2011

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