I. Introduction
A voltage standard that floats relative to Earth potential offers the flexibility to choose the grounding node of a measurement circuit. This feature is important both for a programmable voltage standard (PJVS) [1] used with Kibble balances [2] and more generally for the measurement of a voltage source that is, by construction, referenced to Earth ground (for example a Zener standard on line-power). The leakage resistance to ground of a PJVS system is not infinite. Because a PJVS array requires a current bias, it is always connected to its bias electronics. The bias electronics have an unavoidable leakage current to ground (LCG) error which must be evaluated and reported as a measurement uncertainty. This effect may constitute the largest contributor to the uncertainty budget of direct PJVS comparisons.