Miners and Shippers of

Coal, Sand, Gravel, and

Limestone.

Manufacturers of Portland
Cement, Concrete Blocks,
and Cement Products.

SNYDER ASSOCIATED COMPANIES, INC. Distributors of Contractor's

Equipment.
1 Glade Park East, P.O. Box 1022, Kittanning, PA 16201
Phone: (724) 548-8101 Producers of Natural Gas.

November 15, 2023

Jennifer Granholm, Secretary, US Department of Energy

1000 Independence Ave SW
Washington, DC 20585

Dear Secretary Granholm:

We are writing in reference to the Department of Energy's (DOE) notice of proposed rulemaking (NPRM) published in
the Federal Register on January 11, 2023, regarding energy-efficient standards for distribution transformers. This
proposal mandates the use of amorphous metal (AM) cores instead of Grain-Oriented Electrical Steel (GOES) cores.

Our concern lies in the potential negative impact of this proposal on the resilience of the U.S. electrical grid. AM cores
rely on imports from foreign countries and are not domestically available for production. This dependency on foreign
imports could leave our country vulnerable to production and shipping disruptions, hindering our ability to respond
swiftly to unforeseen grid needs.

Currently, there is only one U.S. facility producing GOES, located in Butler, Pennsylvania, represented by the United Auto
Workers (UAW). The viability of this facility directly affects our ability to respond to urgent electrical needs, such as
those arising from natural disasters.

Under President Biden's leadership, substantial investments have been made in our manufacturing and infrastructure
sectors through acts like the Inflation Reduction Act, CHIPS and Science Act, and the Infrastructure Investment and Jobs
Act. The proposed rule, if implemented, would undermine the goals set by these acts by requiring manufacturers to
source electrical steel from foreign suppliers, weakening our domestic supply chain.

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

Implementation of this proposed rule could jeopardize the Butler, Pennsylvania facility and leave us reliant on foreign
imports, potentially costing over 1,500 jobs for American union workers. This would severely impact our self-sufficiency
and hinder our ability to support anticipated changes in the EV market, supply chains, and manufacturing.

As a fellow employer of over 400 employees, we stand in solidarity with UAW workers at the Butler and Zanesville
Works and urge the Department of Energy to either: 1) withdraw the NPRM and engage in further stakeholder
consultations before proceeding with a new standard, or 2) proceed with a standard that ensures the continued use of
GOES in distribution transformers.

We thank you for your consideration and strongly urge you to take into account the impact of this proposed standard on
American workers, the economy, and national security.

J(1?~~
Mark A. Karenchak
Chief Financial Officer
 ,,,._,;;oCOM~-i
g.,,~~<fs,
; SNYDER~
- ti{ .
~)'- SINCE1941 q,'1/l"',
l',qNNll-lc;'

SNYDER ASSOCIATED COMPANIES, INC.

P.O. Box 1022
Kittanning, PA 16201

Jennifer Granholm, Secretary

US Department of Energy
1000 Independence Ave SW
Washington, DC 20585