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Comments to DOE on Energy Conservation Standards for Distribution Transformers

The Department of Energy (DOE) recently asked for input on energy conservation standards for certain electrical grid equipment. We submitted comments encouraging DOE to continue monetizing the full climate benefits of greenhouse gas emissions reductions.

Distribution transformers are one of the final pieces in the electric power distribution system, adjusting electricity voltage for use in buildings. DOE is seeking input on how it can identify the maximum, economically-justified efficiency level for distribution transformers. In past analyses, such as an energy conservation program for freezer systems in July 2017, DOE made use of the federal Interagency Working Group’s social cost of carbon (SCC) estimates. We encourage DOE to continue to monetize the benefits of greenhouse gas reductions using SCC estimates, which are the best available tool for weighing the significance of climate impacts.