This document discusses the need to improve transformer efficiency standards beyond the EPACT 2005 levels. It provides facts about transformer lifespan compared to other building equipment and shows that transformers represent a small fraction of building costs. Several studies are referenced that show transformers in buildings are often lightly loaded. The document advocates moving efficiency standards from a single minimum level to a system of multiple classes better matched to actual loading profiles. Higher efficiency transformers are shown to reduce losses and operating costs significantly compared to current EPACT/TP1 standards, especially under real-world electronic loads.