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

Denny Wist, CEO of HiPerm LLC, supports delaying the implementation of the new energy conservation standards for distribution transformers. He argues that the current supply chain for high-grade grain oriented electrical steel (GOES) is under stress and that a delay would allow new production facilities to come online, lowering the cost of achieving efficiency goals.

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 Copper Development Association, Inc. provides technical data and analysis regarding the impact of proposed energy conservation standards on distribution transformers. They highlight that while stricter standards increase material costs and transformer dimensions, they result in improved energy savings and support domestic copper supply chain stability.

Southern California Edison supports the Department of Energy's goal of improving energy efficiency but expresses significant concerns regarding supply-chain risks and foreign dependence associated with the transition to amorphous steel. They urge the DOE to incorporate measures that support domestic or allied-nation production capacity to ensure grid reliability and security.

The Northwest Energy Efficiency Alliance (NEEA) supports the amended energy conservation standards for distribution transformers, noting they provide regulatory certainty and foster a more resilient domestic supply chain. They argue that the standards will benefit ratepayers by reducing electricity costs and encourage capital investment in amorphous metal production.

The China WTO/TBT National Notification & Enquiry Center opposes several aspects of the proposed energy conservation standards for distribution transformers. They recommend excluding large-capacity transformers (3,750 kVA and 5,000 kVA) from the scope due to reliability concerns, establishing a systematic exemption mechanism for space/weight constraints, providing alternative compliance pathways, and extending the transition period to 2030 to address supply chain strain.

Eaton, a global power management company with over 30,000 employees, supports the Department of Energy's April 2024 final rule on energy conservation standards for distribution transformers. The company argues for regulatory certainty, domestic supply chain expansion for critical materials, and modernization of the EPCA to avoid repetitive reviews.

Hitachi Energy, a major U.S. transformer manufacturer, opposes the 2029 energy efficiency standards for distribution transformers due to concerns over supply chain reliability, manufacturing capacity, and increased costs. They argue that the standards will lead to bulk buying, extended lead times, and a reliance on offshore imports, and they urge the Department of Energy to suspend the implementation timeline.

ERMCO, Inc., a major manufacturer of distribution transformers, supports the April 2024 final rule establishing energy conservation standards. They argue that maintaining the current framework provides necessary regulatory certainty and supply chain stability while allowing manufacturers sufficient time to invest in and adapt to the 2029 compliance deadline.

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.