2129 N Coast Hwy • P.O. Box 1126 • Newport, OR 97365-0090 • 877-265-3211 • clpud.

org

US DOE;

Central Lincoln opposes the proposed distribution transformer energy conservation standards based on the
following reasons:

1.) The recent supply chain issues we are seeing for distribution transformer delivery times from
manufacturers on a basic three phase transformers were 12 weeks in 2020; however, now are
much longer - ranging from 52 weeks to over 149 weeks.

2.) Some manufacturers are not accepting any new orders due to supply issues as well as capacity.

3.) Pricing for today’s transformers are at an all-time high due to raw material shortages and demand,
making any new regulatory changes; such as, the proposed efficiency standards only would
increase costs to customers and increase delivery times delaying projects even longer.

4.) Overall this is poor timing - The utility industry and ultimately our customers cannot withstand
this kind of set back at this time.

Sincerely,

Shamus J. Gamache P.E.

Director of Engineering