Coalition opposes DOE’s proposed conservation standards for distribution transformers
The U.S. Department of Energy (DOE) should reconsider its intention to increase energy conservation standards for distribution transformers because it could make the shortage of such devices even worse, says a broad coalition of stakeholders in the distribution transformer supply chain.
“We seek your immediate attention on an issue that could significantly impact national security and grid reliability,” the coalition wrote in a Feb. 15 letter sent to U.S. Energy Secretary Jennifer Granholm. “Simply put, this DOE proposal does nothing to address, and is likely to exacerbate, the current distribution transformer shortage crisis.”
The coalition includes the Edison Electric Institute, the American Public Power Association, the National Rural Electric Cooperative Association, the National Electrical Manufacturers Association, Leading Builders of America, the National Association of Home Builders, and the GridWise Alliance.
Specifically, the organizations addressed a Notice of Proposed Rulemaking (NOPR) posted on Jan. 11 by the DOE, which proposes amended, increased energy conservation standards for distribution transformers, which are devices that transfer power from the electrical grid to residences, businesses, and commercial buildings.
The DOE — which is taking comments on the NOPR until March 27 — says that under the Energy Policy and Conservation Act, any new or amended energy conservation standard must be designed to achieve “the maximum improvement in energy efficiency” that DOE determines is technologically feasible and economically justified, and that the new or amended standards must result in a “significant conservation of energy.”
In its NOPR, the DOE has proposed standards that, if adopted, would apply to a wide range of specific distribution transformers manufactured in, or imported into, the United States starting on the date three years after the final rule is published.
“Our organizations agree that energy efficiency standards play an important role in reaching decarbonization benchmarks while transitioning our nation to a clean and increasingly electrified economy,” the coalition wrote. “However, as proposed, the rule would delay the realization of these benefits by worsening supply chain complications already well known to DOE.”
For instance, the coalition members noted that since 2021, they have been communicating with DOE regarding “the severe and ongoing supply chain challenges” that have prolonged and complicated distribution transformer production and availability.
“The inability to quickly manufacture and deliver these critical components threatens the ability of the electric sector to service current and planned housing markets, swiftly recover and restore service following natural disasters, and deliver the benefits of economy-wide electrification,” they wrote.
Additionally, the organizations say that the NOPR would require manufacturers to transition to a different type of steel, which is largely untested, less flexible, and more expensive.
At the same time, the existing supply chain for this alternative steel is limited and mostly foreign-sourced, they wrote.
“This rule would impose unnecessary cost burdens and further delay the delivery of such critical products,” according to their letter.
Pointing to what they called an unprecedented demand for distribution transformers, the organizations urged DOE to maintain the current efficiency levels required for these products.
“Getting these already highly efficient products into the market more quickly should be the highest priority and will result in the realization of electrification benefits much sooner — benefits that will far outweigh any gains achieved through a fractional percentage increase in efficiency,” they wrote.
