NRECA filed comments with the U.S. Department of Energy on its proposal to amend the energy conservation standards for distribution transformers. The proposed rule would essentially mandate shifting the entire market to amorphous core transformers.

NRECA urges DOE to keep the existing standard in place, as permitted by statute, and instead focus on other means for incentivizing amorphous steel core transformers that could allow for potential expansion in the manufacturer market without jeopardizing electric reliability. DOE's top priority should be finding ways to support domestic distribution transformer manufacturers to increase production immediately and to sustain that output over the long term as electrification of the U.S. economy grows.

  • Now is the wrong time for this proposal. The current distribution transformer supply chain serving the utility sector is struggling to meet demand.
  • DOE's NOPR injects harmful uncertainty into the distribution transformer market, upending potential progress in increasing production, just when utilities need manufacturers to be 100% focused on increasing output.
  • DOE's assumptions about the availability of amorphous steel are incorrect and underestimate the ability of the material to be available at a level to meet the utility sector's needs by 2027 when the rule would take effect.
  • The superiority of amorphous steel to grain oriented electrical steel is overstated in DOE's proposal.
  • Forcing the industry to move to amorphous steel core transformers will require several changes to utility operations and impose significant burden in terms of cost and redesign of other equipment. These costs are not adequately accounted for in DOE's analysis.