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Review of a new exception in NEC Section 220.12


I E E E I ndu str y Appl ic ations Mag az in e • july |Aug 201 6 •

or decades, the
application of Na-
tional Electrical Code
(NEC) rules for sizing
services, feeders, and branch circuits
has resulted in unused capacity in
almost all occupancy classes. U.S.
Department of Energy (DOE) data
compiled in 1999 indicate the average
load on building transformers to be
between 10% and 25%. More recent
data gathered by the educational
facilities industry have verified this
claim. Recognizing that aggressive
energy codes are driving energy con-
sumption lower and that larger-than-
necessary transformers create a
larger-than-necessary flash hazard,
the 2014 NEC provided an exception
Digital Object Identifier 10.1109/MIAS.2015.2459090
image licensed by ingram publishing
Date of publication: 2 May 2016
(HVAC) systems. The historic electrical load growth
RMS Average Load Factor
assumptions of 4–5% per year coupled with NEC Section
90.8 requirements for “future expansion and convenience”
20% have not proven to be correct in most cases. The U.S.
15% economy grows much less than the above-noted 4–5% and
10% is growing differently from an electrical power standpoint.
Changes in the nature of the electrical load itself (e.g.,
LED versus incandescent lighting, variable-speed drives ver-



sus across-the-line starters) have also exerted downward




pressure on electrical load densities in commercial build-



ings. This oversizing of branch circuits and feeder circuits

1 can result in inflated installation costs, excessive material

The results of a 1999 study by the Cadmus Group for the use, and energy waste. Simultaneously, occupant availability
Northeast Energy Efficiency Partnership. RMS: root mean demands can increase the likelihood of electricians working
square. on live equipment with h­ igher-than-necessary flash hazard.
Figure 1 is taken from a 1999 U.S. DOE study on trans-
in Section 220.12 that permitted designers to reduce former loading [3]. The study included medium-voltage ser-
transformer kilovoltampere ratings and all related com- vice substation transformers as well as downstream
ponents of the power delivery system. This was a con- 480-208/120-V distribution transformers and reinforced
servative, incremental step in the direction of reduced the findings of the 2010/2011 APPA data-gathering
load density that is limited to light- effort that supplied substantiation for
ing systems. Further study of feeder the proposals presented to the NEC
and branch circuit loading is necessary Code-Making Panel 2 (CMP-2).
to inform discussions about circuit U.S. Department Although the building premise ser-
design methods in future revisions of vice equipment is sized according to
the NEC. of Energy NEC fire safety requirements, the load

Data-Gathering Effort
data compiled that is actually metered by the utility is
significantly different and confirms the
For many years, it has been believed in 1999 indicate 1999 DOE findings and the 2010/2011
that electrical power systems in many APPA findings. Utility service planners
large commercial systems have been the average will usually take a load letter prepared by
designed, specified, and installed the owner requesting, for instance, a util-
IEEE Indus try A pplicat ion s M agazin e • july |Au g 2016 • g/ia s

with more electrical power system load on ity-owned 1,500-kVA exterior pad-
capacity than necessary. If this is the mounted transformer but install a
case, the negative implications would building 1,000-kVA transformer instead because
include higher installation and main-
tenance costs, increased energy con- transformers metering data from similar customer
classes reveal that load computed accord-
sumption from losses, possibly higher to be between ing to NEC Article 220 methods for
arc-flash levels, and excessive use of interior transformers will likely never be
critical resources. 10% and 25%. seen. Overloading of the units is rare but
These many negative implications tolerated by the design of the transform-
caused a data-gathering effort to be ers themselves or avoided altogether with
undertaken by the educational facilities protective devices.
industry during 2010 and 2011 and was organized under
the auspices of the Association of Physical Plant Adminis- New 2014 NEC Language
trators (APPA), Leadership in Educational Facilities. It APPA data-gathering results, among other reasons,
revealed that building electrical systems in the studied encouraged a number of proposals to be submitted to the
facilities have, for at least the past 50 years, very often been technical committees preparing the 2014 revision to the
designed to provide and distribute 15 W/ft2 when, in fact, NEC. The acceptance of two key proposals would pro-
the operational electrical load in these facilities is rarely vide engineers with an exception that permits circuit siz-
above 5 W/ft2. This is statistically significant for the own- ing based on power densities that track energy code
ers of all large commercial facilities like colleges and uni- limitations on lighting loads. The proposal that was
versities because, contrary to expectations with respect to approved was derived from numerous safety concepts
classrooms, laboratories, and athletic facilities, most of the presented by many others in the past four NEC cycles,
square footage in U.S. colleges and universities can be clas- such as the American Chemistry Council and the State of
sified by the building codes as office space. Wisconsin. The successful proposal merely offered a sta-
The energy codes promulgated by the American Soci- tistically significant data set to prove the reasonableness
ety of Heating, Refrigerating, and Air Conditioning Engi- of concepts advanced by others.
neers, Inc. (ASHRAE) [1] and the International Code The disparity between the current NEC rules in
Council [2] are driving down the electrical load allowed Table 220.12 (shown in Figure 2) and the new energy code
by lighting and heating, ventilating, and air-conditioning requirements is not small, as shown in Figure 3, which is a
tabulation of lighting power densities
asserted by the two dominant energy Table 220.12 General Lighting Loads by Occupancy
codes in the United States set against
the NEC requirement for supply cir-
Unit Load
cuit design.
The new exception provides design- Voltamperes/ Voltamperes/
ers with another method for comput- Type of Occupancy Square Meter Square Foot
ing the lighting load for a building.
220.12 Lighting Load for Armories and Auditoriums 11 1
Specified Occupancies. A unit Banks 39 (b) 3½ (b)
load of not less than that speci- 33 3
Barber Shops and Beauty Parlors
fied in Table 220.12 for occu-
Churches 11 1
pancies specified therein shall
constitute the minimum light- Clubs 22 2
ing load. The floor area for each Court Rooms 22 2
floor shall be calculated from Dwelling Units (a) 33 3
the outside dimensions of the Garages––Commercial (Storage) 6 ½
building, dwelling unit, or Hospitals 22 2
other area involved. For dwell-
ing units, the calculated floor Hotels and Motels, Including Apartment 22 2
area shall not include open Houses Without Provision for Cooking
porches, garages, or unused or by Tenants (a)
unfinished spaces not adaptable Industrial Commercial (Loft) Buildings 22 2
for future use. Lodge Rooms 17 1½
Informational Note: The unit
values herein are based on mini- Office Buildings 39 (b) 3½ (b)
mum load conditions and 100% Restaurants 22 2
power factor and may not pro- Schools 33 3
vide sufficient capacity for the Stores 33 3
installation contemplated. Warehouses (Storage) 3 ¼
Exception: Where the build- In Any of the Preceding Occupancies
ing is designed and constructed

I E E E I ndu str y Appl ic ations Mag az in e • july |Aug 201 6 •

Except One-Family Dwellings and
to comply with an energy code
Individual Dwelling Units of Two-Family
adopted by the local authority,
the lighting load shall be per- and Multifamily Dwellings:
mitted to be calculated at the Assembly Halls and Auditoriums 11 1
values specified in the energy Halls, Corridors, Closets, Stairway 6 ½
code where the following condi- Storage Spaces 3 ¼
tions are met:
1) A power monitoring sys- (a)See 220.14(J)

tem is installed that will (b)See 220.14(K)

provide continuous infor- 2
mation regarding the total NEC Table 220.12. © National Fire Protection Association.
general lighting load of
the building.
2) The power monitoring system will be set with
alarm values to alert the building owner or Occupancy NEC ASHRAE IECC
manager if the lighting load exceeds the values
set by the energy code. Office 3.5 0.82 0.90
3) The demand factors specified in 220.42 are not Hospital 2.0 1.05 1.10
applied to the general lighting load.
Both the International Energy Conservation Code (IECC) and School 3.0 0.87 0.99
ASHRAE 90.1 derived their values from the Illuminating 3
Engineering Society guidance [4]. The lighting requirements A comparison of lighting power densities in voltamperes
are specified in terms of foot-candles and lumens, but the (watts)/square foot.
energy codes translate them into watts. The designer must
determine the multiplier that translates foot-candle require-
ments into lighting power densities. New requirements in Despite the very specific conditions under which the
both the ASHRAE and IECC documents are trending toward Section 220.12 exception is permitted, this change in
expanding LED lighting, although the initial cost of LED the 2014 NEC revision is significant. For a 1,000-kVA
lighting is significantly more expensive at the present time. office building service substation, for example, designed
a­ ccording to the 3.5-VA/ft2 guidance given in Table The underutilization of transformers was one of the
220.12, the lighting load may be computed according incentives for the federal legislation directed at transform-
to either 0.82 VA/ft2 (ASHRAE 90.1) or 0.90 VA/ft2 er manufacturers through the Energy Policy Act of 2005.
(IECC) contingent upon the presence of an energy moni- The U.S. DOE understood, correctly, that it would likely
toring system that controls lighting load. These systems be easier to mandate that manufacturers make their prod-
are being installed in most new buildings anyway. In ucts more efficient as opposed to convincing experts on
the case of an office building where lighting was 30% of NEC committees to change the calculation methods that
the load, the estimated 300-kVA demand load would be determined their kilovoltampere rating. The transformer
permitted to be reduced to 75 kVA. When reflected efficiency standards set forth in National Electrical Manu-
in the service substation kilovoltampere sizing, the facturers Association (NEMA) TP-1 2002 were written
­calculation will likely result in the specification of a into public law, making it a requirement for all transform-
750-kVA service substation trans- er manufacturers to meet or exceed
former instead of rounding up to the these efficiencies in all nonexempt
1,000-kVA transformer. The follow- Without units built on or after 1 January 2007.
ing benefits accrue. The DOE further addressed low-volt-
1) L ower kilovoltamperes nearly a doubt, age transformer design by defining
always result in a reduced flash varying levels of transformer efficien-
hazard. there are cies (CSL-1 through CSL-5), with
2) Lower kilovoltamperes reduce the CSL-3 being voluntarily adopted by a
size of switchgear and switchgear installations number of manufacturers through the
rooms. NEMA Premium ­Efficiency Trans-
3) L ower kilovoltamperes mean where former Program [6].
lower heat losses and smaller
HVAC systems and cooling duct-
transformers In the proposal stage of the 2014
NEC revision [the so-called report on
work. with proposals (ROP) stage], the proposal
4) Although relatively rare, a 150-kVA that is the topic of this article (Pro-
dedicated lighting transformer redundant posal 2-228, Log 2914) received three
may now be specified at 50 kVA, negative votes from CMP-2. One com­
requiring a smaller electrical closet. capacity are mittee member rejected the need for a
5) Farther up the grid, avoided no- power monitoring system. A second
load losses at medium voltage necessary. committee member rejected the pro-
represent an approximately posal over a concern that task light-
IEEE Indus try A pplicat ion s M agazin e • july |Au g 2016 • g/ia s

US$43,860 savings (0.5% × ing—supplied from receptacles not

8,760 h/year × US$0.10 kWh × 10,000 kVA) for controlled by the power monitoring system—would
every 10,000 kVA of connected transformers. result in overloading receptacle-only or mixed-use
6) Owners and operators of district energy systems branch circuits. A third committee member rejected the
(such as hospitals and universities) may see a reduc- need for more exceptions to the general methods of Arti-
tion in reactive (kilovar) load. A 1% or 2% higher cle 220. Many industries (e.g., schools, restaurants,
power factor on a 100-MVA grid could save hun- farms, and multifamily-dwelling builders) have excep-
dreds of thousands of dollars per year. tions that add to the complexity of Article 220. In the
ROP stage, Proposal 2-228 passed with a narrow eight-
Counterarguments to-three majority.
The existing NEC calculation methodologies that lead to In the second comment stage of 2014 NEC devel-
transformer oversizing have been difficult to handle opment (the so-called report on comments stage), Pro-
politically, technically, and economically [5]. Until the posal 2-228 picked up two additional affirmative
arguments were presented that flash-hazard safety was votes (with only one dissenting vote regarding the
undermined by importing too much energy into a build- requirement for the power monitoring system). With
ing in the first place, the NEC panel that deals with no dissenting comments coming from public review,
Chapter 2 of the NEC rules was not going to act on this demonstrated significant industry acceptance of
arguments based on energy economics alone. The core the concept. Proposal 2-228 was approved with a final
mission of the National Fire Protection Association ten-to-one vote.
(NFPA) suite of documents is safety.
Without a doubt, there are installations where Related Permissive Statements
transformers with redundant capacity are necessary. It is instructive to understand the evolution of Article 220
Double-ended substations are common in health-care in terms of general rules and the exceptions to general rules
facilities, laboratories, athletic venues, and critical that have evolved over many revisions of the NEC. There
process areas. In high-rise facilities, large fire pumps are three sections in which designers have been permitted
may require larger transformers to continue operation relief from prescriptive design requirements.
in emergencies. These are rare cases, however, and Section 220.87 Determining Existing Loads. The
many of those transformers already have significant calculation of a feeder or service load of an occupancy
overload capability. can be based on the actual measured load if the
designer wants to add electrical load to expand the be informed with as much data as possible and presented
occupancy in square-footage, for example. Designers to the organizations and technical professionals in the
are permitted to use actual metered data of the exist- best position to understand all dimensions of the prob-
ing load when determining the allowable increase in lem as soon as possible.
the service or feeder loads.
Section 430.26 Feeder Demand Factor. Joint IEEE Industrial Applications
Where reduced heating of the conductors results Society/NFPA Project
from motors operating on duty-cycle, intermit- NEC committees have always worked well with IEEE
tently, or from all motors not operating at one committees, and many IEEE Members have votes on
time, the authority having jurisdiction may grant NEC committees. There are currently over 15 refer-
permission for feeder conductors to have an ences to IEEE standards in the 2011 NEC, with a sim-
ampacity less than specified in ilar number in the 2008 version.
430.24, provided the conductors Many of the IEEE Industrial
have sufficient ampacity for the
maximum load determined in
NEC Applications Society (IAS) Color
Books are included in these num-
accordance with the sizes and num- committees bers. The 2011 references include
ber of motors supplied and the the (former) Green Book [7] and the
character of their loads and duties. have always Gold Book [8]. The 2008 NEC also
It is noteworthy that this section con- has specific references to the Gray
tains a reference to IEEE Color Books— worked well Book [9] and the Red Book [10].
documents that are soon to be Section 430.26 of the 2011 NEC
superseded—which have traditionally with IEEE references feeder demand factors. In
been relied upon to contain best prac-
tices for the electrical power industry.
committees, prior years, there were two, possi-
bly more, Red Book and Gray Book
Section 645.25 Engineering Super- and many IEEE references to similar subjects.
vision. Relaxation of Article 220 Unfortunately, the tables that were
rules is permitted for information Members have referred to initially have not been
technology rooms. As an alternative included in either the Red Book or
to the feeder and service load calcula- votes on NEC the Gray Book for many years.
tions required by Parts III and IV of There are no readily available cop-
Article 220, feeder and service load committees. ies of the book version with this
calculations for new or existing loads information. Given the expertise

I E E E I ndu str y Appl ic ations Mag az in e • july |Aug 201 6 •

are permitted to be used if performed now concentrated in the IAS’s
by qualified persons under engineering supervision. Industrial and Commercial Power Systems Depart-
With the exception of Section 645.25, which was new ment (I&CPS), it is in the best position to assist agen-
to the 2008 NEC to accommodate data center design, cies like the NFPA Research Foundation in the
none of these performance clauses seemed to have an effect identification of thought leaders, to work collabora-
upon design overcapacity. A careful look at Section 220 tively with any NEC workgroups during the 2020
and Annex D shows exceptions for farms, residences, and revision cycle, and to present more data to support (or
restaurants, but the largest occupancy class of them all refute) a case for the following concepts:
(i.e., large commercial facilities) has not been permitted an ■■ relaxing the requirement for the energy management
occupancy-specific method to narrow the disparity system in the new exception for the use of Table
between calculated and measured loads. The possible fac- 220.12
tors that can be contributing to the persistent evidence of ■■ reducing the NEC 220.14 per-outlet design requirement
overcapacity in building premise switchgear are as follows. to 120 VA from the present 180 VA.
■■ If HVAC equipment circuit ampere requirements are ■■ revisiting the demand factors of Section 430.26 for sizing
based on Article 440 methods, intended for the field supply switchgear for buildings with multiple HVAC units.
installation of multiple motors, the application of NEC The assistance of the IAS I&CPS is needed in and of itself,
diversity concepts for UL-listed packaged products but it is also specifically needed to assist in the following
where internal controls result in lower ampere require- proposed research project, which requested funding
ments may not be appropriate. through the NFPA Research Foundation in January 2013.
■■ There are no regional or climate-based exceptions to That request has the following goals.
NEC demand factors. Furthermore, organizations such
as ASHRAE, the Air-Conditioning, Heating, and Research Objective
Refrigeration Institute, and the American Society of The objective is to provide updated data for a variety of
Mechanical Engineers have not yet captured in their occupancy and loading types that will inform NEC feed-
leading practice documents the economies of scale in er and branch circuit design requirements in Articles
buildings with multiple HVAC units. 210–230 to size a building power system for safety and
Electrical engineers engage in a long conversation about economy as well as efficiency. Another objective is to
the competing requirements of safety and economy in provide data to inform the assumptions about load diver-
large commercial buildings. That conversation needs to sity in Article 220.
Project Description distributed resource energy supplies) can define a new
It is more difficult to collect feeder and branch circuit package of electrical upgrades, then can be financed,
data than service load data, but this information is need- safely built, and economically run.
ed by the electrical industry to inform technical discus- Perhaps the result of an agreement on updated guide-
sions to keep the 2017 NEC in step with energy codes. lines for circuit design will set in motion a wave of devel-
opment in which transformer retrofits have attractive
Estimated Funding Required for Project payback periods. Such would be the case in building addi-
The estimated cost is US$1.5 million for a staff of eight tions or rehabilitation when old, oversized, and lossy trans-
full-time workers for 18 months. This estimate is based formers can be economically replaced with newer, smaller,
upon a data-gathering effort of similar scale performed for cooler transformers where architectural space permits.
the U.S. Army Corps of Engineers. A scaled-down version Medium-voltage transformers installed in the 1970s and
of this study could involve only the loading of 480/208-V 1980s, for example, that were never loaded to more than
building transformers that supply a mixture of lighting, 25% of rated capacity would be good candidates for
receptacle, and HVAC loads for general commercial occu- replacement with an 800-A, 480-V service that reflects the
pancies. This might cut the cost of the research in half reality of 5 W/ft2 for most commercial facilities.
but would limit the applicability of the results. Designing similar electrical systems to more closely fit
Project deliverables are necessary before the dead- the loads that experience and measurement have shown
line for proposing changes to the 2017 NEC. A com- actually exist in many installations will increase safety and
pletion date of October 2018 was a reasonable target. efficiency and save money. This new approach to design is
This project could draw from recent findings in the a solid, measured step in the right direction. The NEC has
new IEEE 3000 Series Collection [11] and could also succeeded as one of the most widely used technical stan-
contribute to our understanding of electrical demand dards in the world. It is wise to move slowly to see
characteristics in large commercial buildings in an eco- how this change in design methods proves itself and is
nomic environment that is driving power densities integrated into the culture of the electrical industry.
aggressively downward, coupled with a heightened
concern for safety and reliability [12]. References
[1] Energy Standard for Buildings Except Low-Rise Residential Buildings,
Summary ASHRAE 90.1, 2010.
[2] International Code Council, 2010 International Energy Conservation Code.
Approximately 80% of commercial building power sys- Washington, D.C.: ICC, 2010.
tems are using less than half of their installed capacity. [3] United States Department of Energy. (1999). Study of transformer
By permitting engineers the option of trimming back loading in Northeast region. [Online]. Available:
about 30% on Article 220 design rules, we have set the analysis/studies/demand/miscelectric/pdf/miscelectric.pdf
IEEE Indus try A pplicat ion s M agazin e • july |Au g 2016 • g/ia s

[4] D. DiLaura, K. Houser, R. Mistrick, and G. Steffy, Eds., Lighting

stage for running about 80% of building power systems Handbook, 10th ed. New York: Illuminating Engineering Society,
above the 50% mark with offsetting I2R heat losses. Is 2011.
the industry comfortable with this? Running our systems [5] M. A. Anthony, J. R. Harvey, and J. Sanguinetti, “Driving new con-
closer to capacity may raise the levels of required mainte- cepts into the National Electrical Code,” Facilities Manager, vol. 28,
no. 2, pp. 36–37, Mar.–Apr. 2012.
nance. It may also mean that we need to revisit how we [6] Guide for Determining Energy Efficiency for Distribution Transformers,
actually rate electrical apparatus. We recognize that NEMA Standard TP-1, 2002.
many safety concepts, widely scattered in many docu- [7] IEEE Recommended Practice for Grounding of Industrial and Commercial
ments or in unwritten rules of thumb, may have to exist Power Systems, IEEE Standard 142, 1982.
together for a while until the practical effect of this [8] IEEE Recommended Practice for the Design of Reliable Industrial and Commer-
cial Power Systems, IEEE Standard 493, 2007.
change comes into view. [9] IEEE Recommended Practice for Electric Power Systems in Commercial Build-
In rare cases, it is possible that this reduction in service ings, IEEE Standard 241, 1990.
capacity may result in fire accidents in improperly [10] IEEE Recommended Practice for Electric Power Distribution for Industrial
designed and operated systems where overheated equip- Plants, IEEE Standard 141, 1993.
[11] IEEE. (2016). IEEE 3000 Standards Collection™ for Industrial &
ment is not first de-energized by overcurrent devices. ­Commercial Power Systems. [Online]. Available:
Proper designs would eliminate this problem. The gains findstds/3000stds/index.html
(i.e., tens of billions of dollars per year in avoided cost in [12] M. Anthony, P. Ling, and J. Meijer. (2014, May 20). Lightening up on
the United States alone) should be worth it if the offset- lighting loads. Electrical Construction & Maintenance. [Online]. Available:
ting gain is in electrician safety.

Conclusion Michael A. Anthony ( is with the Uni-

For the first time in the history of the NEC, we are see- versity of Michigan, Ann Arbor. Thomas L. Harman is with the
ing energy codes about design in Article 220 being University of Houston–Clear Lake, Texas. James R. Harvey is
deliberated where many assumptions affect safety and with the University of Michigan Health System, Ann Arbor.
cost. There is a large class of rehabilitation possibilities Anthony is a Member of the IEEE. Harman is a Life Member of
in which a single reason is not sufficient for a total the IEEE. Harvey is a Senior Member of the IEEE. This article
upgrade of an electrical service, but several reasons taken first appeared as “Rightsizing the Electrical Power Systems in
together (i.e., reduction in the size of a transformer, Large Commercial Facilities” at the 2013 IEEE IAS 49th
reduction in flash hazard, removal of workspace viola- Industrial and Commercial Power Systems Technical Conference.
tions, desire for smart metering, on-site generation, and  IAS