Low Voltage Distribution Transformers

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> Thomas Patzner Product Manager, Low Voltage Transformers

> Marquette University – Electrical Engineering

> Apprentice Electrician

> Low Voltage Transformers - Co-op (Square D Company) (lab testing, inoperative trouble shooting, designing of units) - Application Engineer (Square D Company) - Sales Engineer (Jefferson Transformer) - Marketing (Square D Company) - Product Manager (Square D Company)

8 The Energy Policy and Conservation Act of 1975 (EPCA), as amended, prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including distribution transformers.

9 EPACT 1992 • Authorized Department of Energy to evaluate Distribution Transformers

Market Response • Energy Star – added Distribution Transformers to program – 1994 • NEMA – publishes Standard for Higher Efficient Transformers - 1996 • States Mandated NEMA Standard Level for Low Voltage Products (1999 through 2005)

Department of Energy • DOE start analysis process • Advance Notice of Public Ruling – July, 2004

EPACT 2005 • Authorized DOE to mandate efficiency levels on Distribution Transformers • Low Voltage Transformers – Mandated to TP1 standard effected Jan, 2007

Market Response • Energy Star Program discontinued May, 2007

Department of Energy • DOE stop all work being done on Low Voltage units from the EPACT1992 • DOE finalized Medium Voltage Final Rule – 2007 – mandating levels effected Jan, 2010 • 10 CFR 431 includes how to test the distribution transformers

• 10 CFR 429 -CERTIFICATION, COMPLIANCE, AND 11 ENFORCEMENT… COMMERCIAL AND INDUSTRIAL EQUIPMENT

Distribution transformer means a transformer that— (1) Has an input voltage of 34.5 kV or less; (2) Has an output voltage of 600 V or less; (3) Is rated for operation at a frequency of 60 Hz; and (4) Has a capacity of 10 kVA to 2500 kVA for liquid-immersed units and 15 kVA to 2500 kVA for dry-type units; but…

Liquid-immersed distribution transformer means a distribution transformer in which the core and coil assembly is immersed in an insulating liquid.

Medium-voltage dry-type distribution transformer means a distribution transformer in which the core and coil assembly is immersed in a gaseous or dry-compound insulating medium, and which has a rated primary voltage between 601 V and 34.5 kV.

Low-voltage dry-type distribution transformer means a distribution transformer that— (1) Has an input voltage of 600 volts or less; (2) Is air-cooled; and (3) Does not use oil as a coolant. 12

Distribution transformer means a transformer that— (5) The term “distribution transformer” does not include a transformer that is an— (i) Autotransformer; (ii) Drive (isolation) transformer; (iii) Grounding transformer; (iv) Machine-tool (control) transformer; (v) Nonventilated transformer; (vi) Rectifier transformer; (vii) Regulating transformer; (viii) Sealed transformer; (ix) Special-impedance transformer; (x) Testing transformer; (xi) Transformer with tap range of 20 percent or more; (xii) Uninterruptible power supply transformer; or (xiii) Welding transformer.

Distribution Transformer

Liquid-immersed Dry-Type (2007 Final Rule)

Low Voltage Medium Voltage EPACT 2005 (2007 Final Rule)

Final Rule – April 2013

14 The ERAC subcommittee for medium voltage liquid-immersed, The ERAC subcommittee for low voltage distribution transformers and dry-type distribution transformers consisted of consisted of representatives of parties having a defined stake in the representatives of parties, listed below, having a defined stake outcome of the proposed standards and included: in the outcome of the proposed standards and included: > ABB Inc. > AK Steel Corporation > AK Steel Corporation > American Council for an Energy-Efficient Economy > American Council for an Energy-Efficient Economy > Appliance Standards Awareness Project > American Public Power Association > ATI-Allegheny Ludlum > Appliance Standards Awareness Project > EarthJustice > ATI-Allegheny Ludlum > Eaton Corporation > Baltimore Gas and Electric > Federal Pacific Company > Cooper Power Systems > Lakeview Metals > Earthjustice > Efficiency and Renewables Advisory Committee member > Edison Electric Institute > Metglas, Inc. > Fayetteville Public Works Commission > National Electrical Manufacturers Association > Federal Pacific Company > Natural Resources Defense Council > Howard Industries Inc. > ONYX Power > LakeView Metals > Pacific Gas and Electric Company > Efficiency and Renewables Advisory Committee member > Schneider Electric > Metglas, Inc. > U.S. Department of Energy > National Electrical Manufacturers Association > National Resources Defense Council > National Rural Electric Cooperative Association > Northwest Power and Conservation Council > Pacific Gas and Electric Company > Progress Energy > Prolec-GE > U.S. Department of Energy 15 10 CFR 431 – April 2013 Final Rule

Conclusion Based on the analyses culminating in this final rule, DOE found the benefits to the nation of the standards (energy savings, consumer LCC savings, positive NPV of customer benefit, and emission reductions) outweigh the burdens (loss of INPV and LCC increases for some users of this equipment). DOE has concluded that the standards in today's final rule represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in significant conservation of energy.

16 10 CFR 431 – April 2013 Final Rule

Liquid-immersed Distribution transformers:

A diversity of core materials are cost TSL 1 competitive and economically feasible for all Design Lines.

TSL 2 EL 1 for all design lines

TSL 3 Maximum efficiency achievable with M3 Steel

TSL 4 Maximum NPV with 7% discounting

TSL 5 EL 3 for all design lines

Maximum source energy savings with TSL 6 positive NPV (7% discounting)

TSL 7 Maximum technologically feasible (max tech) 17 10 CFR 431 – April 2013 Final Rule

Liquid-immersed Distribution transformers:

A diversity of core materials are cost TSL 1 competitive and economically feasible for all Design Lines.

Phase Type Design line TSL Energy efficiency level Efficiency(%) count Liquid-immersed 1 1 1 1 (0.4 actual)* 99.11 2 1 Base (0.5 actual)* 98.95 3 1 1 (1.1 actual)* 99.49 4 3 1 99.16 5 3 1 99.48

18 10 CFR 431 – April 2013 Final Rule

Low Voltage Distribution transformers:

TSL 1 Maximum efficiency achievable with M6 Steel

TSL 2 NEMA Premium Levels (CSL3-2004)

Maximum efficiency achievable using butt lap TSL 3 core mitering for single-phase designs and full mitering for three-phase designs

TSL 4 Maximum NPV with 7% discounting

Maximum source energy savings with TSL 5 positive NPV (7% discounting)

TSL 6 Maximum technologically feasible (max tech)

19 10 CFR 431 – April 2013 Final Rule

Low Voltage Distribution transformers:

TSL 2 NEMA Premium Levels (CSL3-2004)

Phase Type Design line TSL Energy efficiency level Efficiency(%) count Low-voltage dry-type 6 1 2 Base 98.00 7 3 3 98.60 8 3 2 99.02

20 10 CFR 431 – April 2013 Final Rule

Medium Voltage Dry Type Distribution transformers:

TSL 1 EL 1 for all design lines

A diversity of core materials are cost- TSL 2 competitive and economically feasible for all design lines

TSL 3 Maximum NPV with 7% discounting

Maximum source energy savings with TSL 4 positive NPV (7% discounting)

TSL 5 Maximum technologically feasible (max tech)

21 10 CFR 431 – April 2013 Final Rule

Medium Voltage Dry Type Distribution transformers:

A diversity of core materials are cost- TSL 2 competitive and economically feasible for all design lines

Phase Type Design line TSL Energy efficiency level Efficiency(%) count

Medium-voltage dry-type 9 3 2 1 98.93 10 3 2 99.37 11 3 1 98.81 12 3 2 99.30 13A 3 1 98.69 13B 3 2 99.28

22 (a) Low Voltage Dry-Type Distribution Transformers 431.196 Energy conservation standards and their effective (1) The efficiency of a low- (2) The efficiency of a low- voltage, dry-type distribution voltage dry-type distribution dates. transformer manufactured on or transformer manufactured on or after January 1, 2007, but before after January 1, 2016, Low Voltage Distribution Transformers January 1, 2016 . Three Phase set at EL3 and EL2 (NEMA Single-phase Three-phase Single-phase Three-phase PREMIUM, CSL3-2004) levels from the Efficiency Efficiency Efficiency Efficiency DOE engineering analysis kVA (%) kVA (%) kVA (%) kVA (%)

. Single Phase set at Base levels (no 15 97.7 15 97.0 15 97.70 15 97.89 change) from the DOE engineering

analysis 25 98.0 30 97.5 25 98.00 30 98.23 . Minimum Levels of Efficiency at four 37.5 98.2 45 97.7 37.5 98.20 45 98.40 50 98.3 75 98.0 50 98.30 75 98.60 significant digits from three 75 98.5 112.5 98.2 75 98.50 112.5 98.74 (ie - .xxx to .xxxx) 100 98.6 150 98.3 100 98.60 150 98.83 167 98.7 225 98.5 167 98.70 225 98.94 250 98.8 300 98.6 250 98.80 300 99.02 333 98.9 500 98.7 333 98.90 500 99.14 Note 750 98.8 750 99.23 EL = Efficiency Level 1000 98.9 1000 99.28 CSL=Candidate Standard Level

23 (b) Liquid-Immersed Distribution Transformers. 431.196 Energy conservation standards and their effective (1) The efficiency of a liquid- (2) The efficiency of a liquid- immersed distribution immersed distribution dates. transformer manufactured on or transformer manufactured on or after January 1, 2010, but before after January 1, 2016 Liquid-immersed Distribution Transformers January 1, 2016, . EL1 (or lower) levels from the DOE Single-phase Three-phase Single-phase Three-phase engineering analysis Efficiency Efficiency Efficiency Efficiency kVA kVA kVA kVA . Note EL = Efficiency Level (%) (%) (%) (%)

10 98.62 15 98.36 10 98.70 15 98.65

15 98.76 30 98.62 15 98.82 30 98.83 25 98.91 45 98.76 25 98.95 45 98.92 37.5 99.01 75 98.91 37.5 99.05 75 99.03 50 99.08 112.5 99.01 50 99.11 112.5 99.11 75 99.17 150 99.08 75 99.19 150 99.16 100 99.23 225 99.17 100 99.25 225 99.23 167 99.25 300 99.23 167 99.33 300 99.27 250 99.32 500 99.25 250 99.39 500 99.35 333 99.36 750 99.32 333 99.43 750 99.40 500 99.42 1000 99.36 500 99.49 1000 99.43 667 99.46 1500 99.42 667 99.52 1500 99.48 833 99.49 2000 99.46 833 99.55 2000 99.51 24 2500 99.49 2500 99.53 (c) Medium-Voltage Dry-Type Distribution Transformers. 431.196 Energy conservation standards and their effective (1) The efficiency of a medium- (2) The efficiency of a medium- voltage dry-type distribution voltage dry-type distribution dates. transformer manufactured on or transformer manufactured on or after January 1, 2010, but before after January 1, 2016, January 1, 2016,

Single-phase Single-phase

BIL* BIL*

20-45 kV 46-95 kV ≥96 kV 20-45 kV 46-95 kV ≥96 kV kVA kVA

Efficiency Efficiency Efficiency Efficiency Efficiency Efficiency (%) (%) (%) (%) (%) (%) 15 98.10 97.86 15 98.10 97.86 25 98.33 98.12 25 98.33 98.12 37.5 98.49 98.3 37.5 98.49 98.30 50 98.60 98.42 50 98.60 98.42 75 98.73 98.57 98.53 75 98.73 98.57 98.53 100 98.82 98.67 98.63 100 98.82 98.67 98.63 167 98.96 98.83 98.8 167 98.96 98.83 98.80 250 99.07 98.95 98.91 250 99.07 98.95 98.91 333 99.14 99.03 98.99 333 99.14 99.03 98.99 500 99.22 99.12 99.09 500 99.22 99.12 99.09 667 99.27 99.18 99.15 667 99.27 99.18 99.15 833 99.31 99.23 99.20 833 99.31 99.23 99.20 25

431.196 Energy conservation standards and their effective dates. Medium-Voltage Distribution Transformers . Three Phase set at EL1 and EL2 levels from the DOE engineering analysis . Negotiate Levels with all stack holders Note EL = Efficiency Level

26 Form / Fit / Function

Low Voltage Distribution Transformers Comparing actual existing designs to new product offering available in 2016. DL7 (75kVA) DL8 (300kVA) These are Schneider Electric comparison, other manufactures might have different changes

Liquid-immersed Distribution Transformers DL5 (1500kVA)

Medium Voltage Dry-Type Distribution Transformers DL12 (1500kVA)

27 Design Line 7, 75kVA, Aluminum, 150°C / 220 Ins F Top Ventilation front only, O Primary / Secondary Terminals separated, R (meet all NEC bending requirements side and bottom entry) M Mounting Bracket

Square D: EE75T3H Square D: EX75T3H

F H – 37” H – 42” I W – 30” W – 30.63” T D – 20” D – 22.75” Weight - 585 pounds Weight - 710 pounds

F 98.0% Efficient @ 35% Loading 75°C 98.60% Efficient @ 35% Loading 75°C U N IZ – 3.7% 5.6k 10kAIC IZ – 5.88% 3.5k 10kAIC C Inrush – 10X Rated Inrush – 5.7X Rated T Core Loss: 253 Watts Core Loss: 128 Watts I Coil Loss: 2518 Watts Coil Loss: 2219 Watts O BTU’s @ 75% Load: 5695 BTU’s @ 75% Load: 4695 N Sound Level: 50dB Sound Level: 47dB

28 Design Line 8, 300kVA, Aluminum, 150°C / 220 Ins F Ventilation front only, O Open Bottom increase access R Primary / Secondary Terminals separated, M (meet all NEC bending requirements side and bottom entry) Mounting Bracket Square D: EE300T3H Square D: EX300T3H

F H – 49.5” H – 57.5” I W – 41” W – 40.1” T D – 32” D – 32.75” Weight – 1350 pounds Weight - 1975 pounds

F 98.6% Efficient @ 35% Loading 75°C 99.02% Efficient @ 35% Loading 75°C U N IZ – 5.9% 14.1k 18kAIC / 22kAIC IZ – 4.95% 16.8k 18kAIC / 22kAIC C Inrush – 8.7X Rated Inrush – 5.4X Rated T Core Loss: 831 Watts Core Loss: 479 Watts I Coil Loss: 6584 Watts Coil Loss: 4674 Watts O BTU’s @ 75% Load: 15472 BTU’s @ 75% Load: 10605 N Sound Level: 55dB Sound Level: 52dB

29 Design Line 5, 1500 KVA, Aluminum, 65C Rise, 120 Insulation F Liquid Filled Padmounted O Mineral Oil R Bottom Entry, NEMA 3R Rated M 24940GY/14400V Primary, 480Y/277 Secondary

Square D 2010 Efficiencies Square D 2016 Efficiencies

F H –72.5” H –72.5” I W –86” W –80” T D – 70” D – 66” Weight –10,030 pounds Weight –10,700 pounds

F 99.42% Efficient @ 50% Load 99.48% Efficient @ 50% Load U N IZ – 5.75% IZ – 5.75% C Core Loss 1942 Watts Core Loss 1773 watts T Coil Loss 10488 Watts Coil Loss 7944 I BTU’s @ 50% Load 14,717 BTU’s@50% Load 12,179 O N

30 Design Line 10, 1500 kVA VPI, 150 Rise, 45KV BIL, 220 Insulation F VPI, Power Dry, Substation Transformer O Close Coupled to Primary and Secondary Gear R NEMA 1 Indoor M 4160 Delta Primary, 480 Wye Secondary

Square D 2010 Efficiencies Square D 2016 Efficiencies

F H –94” H –100” I W –84” W –96” T D – 54” D – 60” Weight –6,800 pounds Weight –9,374 pounds

F U 99.12% Efficient @ 50% Load 99.30% Efficient @ 50% Load N C IZ – 5.75% IZ – 5.75% T Core Loss 3600 Watts Core Loss 3000 Watts I Coil Loss 16500 Watts Coil Loss 10600 Watts O BTU’s @ 50% Load 22,993 BTU’s @ 50% Load 17,118 N

31 Codes and Standard – Low Voltage Transformers • National Electrical Code • NEMA ST-20 • NEMA TP1, TP2, TP3

32 NEC Updates

> NEC change 1.2kV units from 600 Volt Max to 1000 Volt Max > 450.9 Ventilation > 450.10 Grounding > 450.11 Markings > 450.12 Terminal wiring space

33 450.9 Ventilation

> The ventilation shall be adequate to dispose of the transformer full- load losses without creating a temperature rise that is in excess of the transformer rating > Transformers with ventilation openings shall be installed so that the ventilating openings are not blocked by walls or other obstructions > The required clearances shall be clearly marked on the transformer November 1992 – UL 1561 was modified an mandated that the minimum distance be 6 inches unless the manufactured alcove tested the units at a different distance, Expect to see distances at less than 6” in the market place with product being completely redesigned.

> Square D Low Voltage Units – all tested at ½” Clearance in alcove

34 450.10 Grounding

> (A) Dry Type Transformer Enclosures. Where separate equipment grounding conductors and supply-side bonding jumpers are installed, a terminal bar for all grounding and bonding conductor connections shall be secured inside the transformer enclosure. The terminal bar shall be bonded to the enclosure in accordance with 250.12 and shall not be installed on or over any ventilated portion of the enclosure.

35 450.11 Markings

(A) General. Each transformer shall be provided with a nameplate giving the following information (1) Name of Manufacturer (2) Rated kilovolt amperes (3) Frequency (4) Primary and Secondary voltage (5) Impedance of transformer 25kVA and Larger (6) Required clearance for transformers with ventilated openings (7) Amount and kind of insulating liquid where used (8) Dry-Type transformer, temperature class for the insulation system

(B) Source Marking. A transformer shall be permitted to be supplied at the marked secondary voltage, provided that the installation is in accordance with the manufacturer's instructions.

36 450.12 Terminal wiring Space

> Minimum wire bending space at fixed, 1000-volt and below terminals of transformer line and load connections shall be as required by 312.6 > TERMINAL: (A) a conducting element of an equipment or a circuit intended for connection to an external conductor (B) a device attached to a conductor to facilitate connection with another conductor > Most transformers require that the raceways be brought into the transformer case in a certain area. > This is usually the lower half of the transformer case.

37 NEMA ST-20 > NEMA Publishes Reinstated NEMA ST 20-2014 Dry Type Transformers for General Applications – June 2014 > The reinstated and revised edition of NEMA ST 20 applies to single-phase and polyphase dry-type transformers (including autotransformers and non-current-limiting reactors) for supplying energy to power, heating, and lighting circuits, and designed to be installed and used in accordance with the National Electrical Code®. It also covers transformers with or without accessories having ratings of 1.2 kV class, 0.25 kVA through 4000 kVA > NEMA ST 20 is one of the few standards in the marketplace that specifically addresses sound levels for this particular type of transformer. > C57-12.01 IEEE Standard General Requirements for Dry-Type Distribution and Power Transformers Including Those with Solid- Cast and/or Resin-Encapsulated Windings > This standard is intended as a basis for the establishment of performance, interchangeability, and safety requirements of equipment described, and for assistance in the proper selection of such equipment. Electrical, mechanical, and safety requirements of ventilated, nonventilated, and sealed dry-type distribution and power transformers or autotransformers (single and polyphase, with a voltage of 601 V or higher in the highest voltage winding) are described. The information in this standard applies to all dry-type transformers

38 NEMA ST-20 > NEMA Publishes Reinstated NEMA ST 20-2014 Dry Type Transformers for General Applications – June 2014 > The reinstated and revised edition of NEMA ST 20 applies to single-phase and polyphase dry-type transformers (including autotransformers and non-current-limiting reactors) for supplying energy to power, heating, and lighting circuits, and designed to be installed and used in accordance with the National Electrical Code®. It also covers transformers with or without accessories having ratings of 1.2 kV class, 0.25 kVA through 4000 kVA > NEMA ST 20 is one of the few standards in the marketplace that specifically addresses sound levels for this particular type of transformer.

39 NEMA TP1, TP2, TP3

> NEMA TP1 DOE Final Rules 10 CFR 429 and 431 > Provides the basis for determining the energy efficiency of certain single- and three-phase dry- > 10 CFR 429 type and liquid-filled distribution transformers and assists with the proper selection of such > Provisions for Statistical Sampling Plans for equipment. Certification Testing > NEMA TP2 - 10 CFR 429.47 > Standard Test Method for Measuring the Energy - 10 CFR 429.70 Consumption of Distribution Transformers. The > APPENDIX C TO SUBPART C OF PART 429: document provides a standardized method for SAMPLING PLAN FOR ENFORCEMENT measurement of distribution transformer loss to TESTING OF DISTRIBUTION achieve energy efficiency levels outlined in NEMA TRANSFORMERS publication TP 1, Guide for Determining Energy Efficiency for Distribution Transformers > 10 CFR 431 > NEMA TP3 > Subpart K—Distribution Transformers > Defines the labeling of distribution transformers > Appendix A to Subpart K of Part 431—Uniform tested to the efficiency levels specified in TP1 Test Method for Measuring the Energy Consumption of Distribution Transformers

40 NEMA TP1, TP2, TP3

DOE Final Rules 10 CFR 429 and 431

> 10 CFR 429 > Provisions for Statistical Sampling Plans for Certification Testing - 10 CFR 429.47 - 10 CFR 429.70 > APPENDIX C TO SUBPART C OF PART 429: SAMPLING PLAN FOR ENFORCEMENT TESTING OF DISTRIBUTION TRANSFORMERS > 10 CFR 431 > Subpart K—Distribution Transformers > Appendix A to Subpart K of Part 431—Uniform Test Method for Measuring the Energy Consumption of Distribution Transformers

41 Low Voltage Transformer Market Conditions • Harmonics (HMT and K-rated) • Copper Windings • Electrostatic Shields • Efficiency Better Than Law

42 Harmonic Load Applications

K-Rated (1990 through now) Harmonic Mitigation Transformers

> Early 90’s UL 1561 determine method for > Leverage Drive Process for single phase testing for harmonic loads harmonic Loads > UL Listing for 4, 9, 13, 20, 30 > 0°, 30°, 15°, 45° (-15°) - Readily available from the Market 4 and 13 > Initial Launch 90’s, not successful – > Over the last 25+ years Delta – Wye and HMT convert the tripplen > Reduction in Harmonic Profiles with harmonics equally electronic equipment > Never really accepted for 5th and 7th Harmonics > Impact of source impedance on K-factor on > Energy Impact added in 21st Century Transformers > Increase Value over Delta-Wye > K-7, is the maximum level seen by a 100% > Voltage Distortion lessen with HMT load transformer

> Should be K-rated, device sees harmonic > K-9 rated should be the level to meet the loads on the Secondary Windings market conditions

43 Delta to Wye 30° Shift Delta to ZigZag 0° Shift

> Primary wave form – No Tripplens > Primary wave form – No Tripplens

44 Copper Windings vs Aluminum Windings

> Truths > Myths > Properly terminating line and load > Aluminum-wound transformer terminations are connections is more difficult for aluminum- incompatible with copper line and load cables wound transformers > Line and load connections to copper-wound > Aluminum wound transformers are lighter in transformers are more reliable than those to weight than copper wound equivalents aluminum wound transformers

> Copper-wound transformers can be made > Aluminum-wound transformers have higher smaller than aluminum wound equivalents. losses because copper is a better conductor

> Aluminum-wound transformers have higher hot- spot temperatures because copper is a better thermal conductor X than aluminum

45 Electrostatic Shield

Transformers shall be supplied with quality, full width electrostatic shields resulting in a maximum effective coupling capacitance between primary and secondary of 33 picofarads. With transformers connected under normal, loaded operating conditions, the attenuation of line noise and transients shall equal or exceed the following limits: Common Mode: 0 to 1.5kHZ - 120dB 1.5kHZ to 10kHZ - 90dB 10kHZ to 100kHZ - 65dB 100kHZ to 1MHZ - 40dB

Transverse Mode: 1.5kHZ to 10kHZ - 52dB 10kHZ to 100kHZ - 30dB 100kHZ to 1MHZ - 30dB

46 Electrostatic Shield

Transverse Mode: 1.5kHZ to 10kHZ - 52dB 10kHZ to 100kHZ - 30dB 100kHZ to 1MHZ - 30dB

Above is DC testing and verification – completed in the late 80’s 47 Electrostatic Shield

Technology Allows for AC Testing of the shield

Schneider Electric White paper 0150PD9603

AC testing has shown that shielding may have little value or no benefits when the secondary is grounded per the NEC requirements. (Wye, ZigZag, and Center Tap Delta Secondaries)

Proper grounding practices, as well as placing isolation transformers as close as possible to loads, are two major factors in providing high quality power to sensitive electronic equipment. 48 Better than the Law

> 2007 to 2016 – NEMA PREMIUM, CSL3 > Justified by the DOE Advance rule in July 2004 > What about in 2016 > DOE has concluded that the standards in today's final rule represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in significant conservation of energy. - 10,000 Designs at multiple Efficiency Levels - All review at the Market Loading Conditions Low Voltage 15 to 20% (Law still sets standard at 35%) > Comparisons need to be to EL3 and EL2 – which become law in 2016 Not EL0 (which is the base – TP1 Levels) > Before you agree to levels above > Review the full FINAL RULE (102 page document) > DOE to announce in 2016 if they will start reviewing Low Voltage – wait till they start there anlyisis 49