You may be surprised to hear that Distribution Transformers (which include the round barrel-looking devices on telephone poles) offer significant energy savings opportunities. Although most transformers are quite efficient (efficiencies over 98%), the sheer volume of these deployed throughout the country mean even small improvements can result in big savings. A few weeks ago, DOE published proposed efficiency standards for Distribution Transformers (This product class is made up of 3 categories of transformers; Medium-voltage liquid-immersed, Medium-voltage dry-type, Low voltage dry-type). Besides the document containing surprising errors and misrepresentations, the proposed levels selected by the Department fell at the very low end of the levels considered. The 30-year savings at the proposed levels are estimated at 50 TWh and $3.7 billion, nationally. Standards at the levels suggested by advocates and manufacturers would produce 4X the savings or 200 TWh and $14 billion over 30 years. In their proposal, the Department repeatedly pointed to the uncertainty about the availability and price of amorphous steel as their justification for selecting the low standard levels. Not only do the economics for consumers (electric utilities, in this case) support higher levels, but the manufacturers of transformers have stated their confidence in securing the needed materials to make far more aggressive standard levels appropriate. ASAP, ACEEE, NRDC, and Earthjustice issued a joint press release calling out DOE for the weak standards and the overemphasis on 'unsubstantiated fears' about the steel. Fortunately, this rulemaking is not yet at its final stage. With strong support for higher levels, the DOE can change their proposal to reflect our regions interest in cost effective energy savings. DOE will be holding a public hearing on their proposed rule on February 23rd. NEEP plans to attend remotely by webinar and provide written feedback to the Department.