2026-07-15 Comment response to the published Request for information

Summary: The American Iron and Steel Institute (AISI) opposes the proposed energy conservation standards for distribution transformers, arguing that the April 2024 rule provides minimal efficiency benefits while undermining domestic grain oriented electrical steel (GOES) production. They contend that the mandate to transition to amorphous metal threatens national security, harms domestic manufacturing, and increases reliance on foreign-sourced materials.