American Iron and Steel Institute (AISI)
Trade associationOppose
Distribution transformer standards
Energy distribution network
National defense readiness
2026-06-15 Energy Conservation Program: Energy Conservation Standards for Distribution Transformers; Request for information
EERE-2026-BT-STD-0133-0001RFI
Comments
31
Last activity Jul 16, 2026
Deadline
Closed on Jul 16, 2026
Closed Jul 16, 2026
Net supportiSupport minus oppose · campaigns included
+35%
+35% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- 2026-06-15 Energy Conservation Program: Energy Conservation Standards for Distribution Transformers; Request for information
- Posted
- Jun 15, 2026
- Comment period
- Jun 15, 2026 – Jul 16, 2026
- FR Doc
- 2026-11971
- CFR
- 10 CFR Part 431
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Stance breakdown
+35%
Net support
Support19Oppose8Other4
Aggregates include form-letter campaigns. Excluding them, net support is +35% across organic comments.
Who commented
Breakdown by commenter type.
Union
1
Business
18
Government
1
Individual
2
Advocacy
3
Trade association
6
Comments over time
Weekly arrivals, stacked by stance.
Posted Jun 15, 2026Deadline Jul 16, 2026
Jun 15Jun 22Jun 29Jul 6Jul 13
Support19Oppose8Other4
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Business
67%
22%
11%
Trade association
67%
33%
0%
Advocacy
67%
33%
0%
Individual
0%
0%
100%
Union
100%
0%
0%
Government
0%
100%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Distribution transformer standards | Energy distribution network | National defense readiness | Transformer technology validation | Tri-generation energy storage systems |
|---|---|---|---|---|---|
American Iron and Steel Institute (AISI) Trade associationOppose The American Iron and Steel Institute (AISI) opposes the proposed energy conservation standards for distribution transfo | · | · | |||
American Public Power Association (APPA) Trade associationSupport The American Public Power Association (APPA) supports the current distribution transformer efficiency standards adopted | · | · | · | · | |
China WTO/TBT National Notification & Enquiry Center GovernmentOppose The China WTO/TBT National Notification & Enquiry Center opposes several aspects of the proposed energy conservation sta | · | · | · | · | |
Cleveland-Cliffs Inc. BusinessOppose Cleveland-Cliffs Inc., a leading American supplier of Grain-Oriented Electrical Steel (GOES), opposes the 2024 energy co | · | · | · | ||
Climate Risk Analytics, LLC BusinessSupport Climate Risk Analytics, LLC (CRA) supports the proposed action and advocates for the inclusion of their "HOOP Tri-Genera | · | · | · | · | |
Eaton Corporation BusinessSupport Eaton, a global power management company with over 30,000 employees, supports the Department of Energy's April 2024 fina | · | · | · | · | |
Edison Electric Institute Trade associationSupport The Edison Electric Institute, representing U.S. | · | · | |||
Electric Research and Manufacturing Cooperative, Inc. BusinessSupport ERMCO, Inc., a major manufacturer of distribution transformers, supports the April 2024 final rule establishing energy c | · | · | · | ||
ENODA Ltd. BusinessSupport ENODA, an energy system innovator, supports the DOE's energy conservation standards for distribution transformers. | · | · | |||
Hitachi Energy BusinessOppose Hitachi Energy, a major U.S. | · | · | · | ||
Howard Industries, Inc BusinessSupport Howard Industries, Inc., a major domestic distribution transformer manufacturer, supports maintaining the April 2024 Fin | · | · | · | ||
Metglas Inc. BusinessSupport Metglas, Inc. | · | · | |||
MGM Transformers by Forgent BusinessOppose Mike Iman of MGM Transformers (Forgent) argues that the DOE's 2029 efficiency requirements for distribution transformers | · | · | · | · | |
National Electrical Manufacturers Association (NEMA) Trade associationSupport The National Electrical Manufacturers Association (NEMA) supports maintaining the certainty of the 2024 final rule for d | · | · | |||
National Rural Electric Cooperative Association Trade associationOppose The National Rural Electric Cooperative Association (NRECA) opposes the initiation of a new rulemaking for distribution | · | · | · | · | |
Northwest Energy Efficiency Alliance (NEEA) AdvocacySupport The Northwest Energy Efficiency Alliance (NEEA) supports the amended energy conservation standards for distribution tran | · | · | · | · | |
Persistence Analytics Group LLC BusinessSupport Persistence Analytics Group LLC argues that the DOE's Request for Information on distribution transformer standards shou | · | · | · |
American Public Power Association (APPA)
Trade associationSupport
Distribution transformer standards
China WTO/TBT National Notification & Enquiry Center
GovernmentOppose
Energy distribution network
Cleveland-Cliffs Inc.
BusinessOppose
Distribution transformer standards
National defense readiness
Climate Risk Analytics, LLC
BusinessSupport
Tri-generation energy storage systems
Eaton Corporation
BusinessSupport
Distribution transformer standards
Edison Electric Institute
Trade associationSupport
Distribution transformer standards
Energy distribution network
National defense readiness
Electric Research and Manufacturing Cooperative, Inc.
BusinessSupport
Distribution transformer standards
National defense readiness
ENODA Ltd.
BusinessSupport
Distribution transformer standards
Energy distribution network
Transformer technology validation
Hitachi Energy
BusinessOppose
Distribution transformer standards
Energy distribution network
Howard Industries, Inc
BusinessSupport
Distribution transformer standards
National defense readiness
Metglas Inc.
BusinessSupport
Distribution transformer standards
Energy distribution network
National defense readiness
MGM Transformers by Forgent
BusinessOppose
Distribution transformer standards
National Electrical Manufacturers Association (NEMA)
Trade associationSupport
Distribution transformer standards
Energy distribution network
National defense readiness
National Rural Electric Cooperative Association
Trade associationOppose
Distribution transformer standards
Northwest Energy Efficiency Alliance (NEEA)
AdvocacySupport
Energy distribution network
Persistence Analytics Group LLC
BusinessSupport
Distribution transformer standards
Transformer technology validation
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- Jul 15, 2026ENODA Ltd.SupportBusiness📎 Attachment
ENODA, an energy system innovator, supports the DOE's energy conservation standards for distribution transformers. They argue that their proprietary Enoda PRIME® Exchanger can meet these standards using domestic materials and offer a cost-effective, drop-in solution that strengthens the domestic supply chain and grid reliability.
Read comment → - Jul 10, 2026MGM Transformers by ForgentOpposeBusiness📎 Attachment
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.
Read comment → - Jun 26, 2026Persistence Analytics Group LLCSupportBusiness
Neil P. Osnato of Persistence Analytics Group LLC suggests that the DOE consider emerging transformer and conductor-insulation technologies, such as ceramic-coated aluminum. He recommends that the DOE establish a technology-validation pathway to verify these innovations for domestic manufacturing resilience and performance.
Read comment →