A Proposal to Modify DOE’s Proposed Distribution Transformer Standard

According to a letter to the United States Department of Energy (DOE) in late March, commenting on DOE’s proposed “Energy Conservation Program: Energy Conservation Standards for Distribution Transformers” standard, the Edison Electric Institute (EEI) warned that finalizing these proposed stricter energy efficiency requirements for distribution system transformers could threaten grid reliability if DOE moves too quickly. Currently, the proposed standard is set to go into effect in 2027.

According to the EEI letter, the main problem is that DOE’s plan would require new liquid-immersed distribution transformers to use amorphous core steel. However, according to the EEI, the U.S. does not currently produce enough of this type of steel, making replacements hard to come by. “Improved transformer efficiency is important but cannot come at the expense of reliability,” wrote EEI.

EEI’s March 27 letter, written and signed by Scott Aaronson, EEI’s senior vice president, security and preparedness, and addressed to Jeremy Dommu and Matthew Ring at the DOE, noted that EEI members represent all U.S. investor-owned electric companies, provide electricity to about 220 million Americans, operate in all 50 states and the District of Columbia, and support more than seven million jobs in communities across the U.S.

The letter went on to say that EEI is committed to clean energy, stating that: “EEI member companies are proud to provide America’s resilient clean energy and to be leading the transformation of energy. Fifty-one EEI members have announced forward-looking carbon reduction goals, 41 of which include a net-zero by 2050 or earlier equivalent goal, and members are routinely increasing the ambition or speed of their goals or altogether transforming them into net-zero goals.”

However, again, EEI noted that it is concerned that DOE’s proposed standard could pose challenges for the electric utility industry. “EEI and its members are deeply concerned about the impacts that the timing and scope of change required by the proposed rule will have on electric companies’ ability to continue to meet their obligation to serve amid a number of supply chain constraints and on our ability to continue the important work of the clean energy transition,” said the letter.

“As further detailed in EEI’s comments, there are several alternatives to finalizing the proposed rule that would allow DOE to accomplish its goals while supporting the Administration’s and the industry’s clean energy goals.”

In specific, instead of finalizing the proposed rule, the EEI recommends that DOE should either:

1 – adopt a lower trial standard level (TSL) that does not require a full move to amorphous steel; or

2 – use its authority to issue a final determination that no new standard is required, which DOE then would be required to revisit within three years.

“In the interim period, and under either scenario, the Department should take decisive action to build critical domestic supply chain capacity now by investing significant funding to build up domestic supply chains and steel production capabilities,” said the letter.


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