Comment response to the published Request for information

Summary: Mike Iman of MGM Transformers (Forgent) argues that the DOE's 2029 efficiency requirements for distribution transformers are too ambitious to meet by the proposed deadline. The company highlights significant technical hurdles, including the need to switch to amorphous steel, which faces supply chain limitations and requires extensive redesigns and manufacturing overhauls. They recommend delaying the implementation of these standards until 2032 or until adequate supply of amorphous steel is available.