Concerning Energy Efficient Standards for Distribution Transformers

Jennifer Granholm Secretary US Department of Energy

WHY Sign...

UAW Local 3303 and Cleveland Cliffs Butler Facility in Pennsylvania, is the only United States manufacturer of Grain-Oriented Electrical Steel (GOES), the metal found in electrical distribution transformers.

The Department of Energy (DOE) is in the process of a proposed rulemaking concerning efficiency standards for distribution, part of that standard will be the use of GOES vs. amorphous metal (AM). GOES is the most efficient steel in high-volume distribution.

AM cores are imported by foreign countries. With no domestic supplier of AM cores, our electrical grids will be reliant on an import supply chain, and shipping issues that will limit our country’s ability to respond when unforeseen circumstances impact our electrical grid.

We urge you to sign our petition asking the DOE to proceed with a standard that ensures the continued use of the GOES in distribution transformers.

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To: Jennifer Granholm Secretary US Department of Energy
From: [Your Name]

We are writing regarding the Department of Energy’s (“DOE”) notice of proposed rulemaking (“NPRM”) concerning energy efficient standards for distribution transformers that was published in the Federal Register on January 11, 2023. This proposed rule would require use of amorphous metal (“AM”) in lieu of Grain-Oriented Electrical Steel (“GOES”) for distribution transformer cores.

We are concerned that DOE’s proposal would be detrimental to the resiliency of the electrical grid throughout the United States as the AM cores are produced from materials imported from foreign countries and is not domestically available for production. Use of AM cores will result in reliance on foreign imports to supply our electrical grid and leave the United States vulnerable to production and shipping issues which will negatively impact our Country’s ability to respond to unforeseen needs within the electrical grid in a rapid fashion.

We understand that there is currently a single facility in the United States which produces GOES which is in Butler, Pennsylvania and which is represented by the United Auto Workers (“UAW”). A sister Plant, the Zanesville Works provides finishing services for GOES material and is also represented by the UAW. The Butler and Zanesville facilities of Cleveland Cliffs are the only domestic producer of GOES and their ability to continue to produce GOES has a direct impact on the ability of the United States to respond to urgent electrical needs such as those caused by natural disasters.

Under President Biden’s leadership, we are seeing generational investments in our country’s manufacturing and infrastructure. The Inflation Reduction Act, CHIPS and Science Act, and the Infrastructure Investment and Jobs Act provide tax credits, federal grants, and loans to produce electric vehicles (“EVs”), EV charging infrastructure, semiconductors, and electricity grid resilience. If the proposed rule is made effective, the ability to provide the AM cores will be a significant detriment to the goals laid out through the Acts. The proposed rule would require manufacturers all along the supply chain to source electrical steel from foreign suppliers and would significantly weaken our domestic supply chain. Even the small volume of AM capacity is dependent on imports of key substrates from foreign countries.

The Department of Commerce has twice identified the preservation of GOES production domestically as a national security imperative.

If the proposed rule would be implemented, it is likely that the viability of the facility in Butler Pennsylvania would be jeopardized, and the ability to domestically respond to natural disasters and infrastructure needs would be wholly dependent on foreign imports.

The proposed rule will destroy the domestic supply chain for distribution transformers, will potentially shutter the Butler and Zanesville Works of Cleveland Cliffs, costing in excess of 1,500 jobs to American union workers. The proposed rule will create an irreparable harm to the self-sufficiency of the United States and will create supply chain, manufacturing, and the ability to support EV market changes which are currently anticipated.

We stand with the UAW workers at the Butler and Zanesville Works in their opposition to the proposed rule, and we respectfully urge the Department of Energy to either: 1.) withdraw the NPRM and conduct additional stakeholder consultation before proceeding with a new standard; or 2.) proceed with a standard that ensures continued use of GOES in distribution transformers.

We thank you for your consideration and urge in the strongest possible terms consideration for the impact of this proposed standard on workers, the United States economy, and on the United States national security.