2026-06-15 Energy Conservation Program: Energy Conservation Standards for Distribution Transformers; Request for information

Howard Industries, Inc., a major domestic distribution transformer manufacturer, supports maintaining the April 2024 Final Rule as issued. They argue that the company has already invested over $180 million in compliance and that preserving regulatory certainty is essential for domestic manufacturing and national security.

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.

The Breakthrough Institute opposes the 2024 Rule's efficiency standards because they compound with existing tariffs and load growth to create supply chain fragility and national security risks. They argue that the standards pull the market toward materials that the sole domestic producer cannot provide, and they recommend a feasibility reassessment of the 2029 compliance deadline and grade-specific data collection.

A coalition of advocacy groups (ASAP, CFA, Earthjustice, and NCLC) supports the existing distribution transformer efficiency standards, arguing they provide regulatory certainty, improve grid resilience, and benefit ratepayers. They argue that supply chain issues are unrelated to these standards and urge the DOE not to use Section 504 of the Department of Energy Organization Act to weaken the rules.

Cleveland-Cliffs Inc., a leading American supplier of Grain-Oriented Electrical Steel (GOES), opposes the 2024 energy conservation standards for distribution transformers. The company argues that the standards mandate a shift to Amorphous Metal (AM) cores that will increase costs, weaken domestic supply chains, and compromise national security by increasing dependence on foreign materials.

Metglas, Inc. supports the Department of Energy's 2024 transformer standards and urges the DOE to maintain them. The company argues that the current standards promote domestic production, enhance national security by reducing reliance on foreign supply chains, and provide significant energy savings and grid capacity.

The Edison Electric Institute, representing U.S. investor-owned electric companies, supports maintaining the existing Final Rule for distribution transformer standards but requests greater flexibility regarding compliance timelines and scope. They argue that current supply chain constraints, rising costs, and accelerated electricity demand growth make the existing deadlines difficult to meet without jeopardizing grid reliability.

The National Electrical Manufacturers Association (NEMA) supports maintaining the certainty of the 2024 final rule for distribution transformer energy conservation standards. They argue that reopening or revising the rule would disrupt significant industry investments and supply chain stabilization, and they advocate for statutory reforms to remove these products from the mandatory EPCA review cycle.

James Sychak, President of UAW Local 3303, supports the preservation of domestically sourced Grain Oriented Electrical Steel (GOES) in distribution transformers. He argues that moving toward amorphous metal cores threatens supply chain security, increases costs, and relies on foreign materials dominated by China.

The National Rural Electric Cooperative Association (NRECA) opposes the initiation of a new rulemaking for distribution transformer efficiency standards. They urge the Department of Energy to maintain the 2024 rule to provide regulatory certainty for manufacturers and utilities preparing for the 2029 compliance date.