Citing poor cost predictions made during past rulemakings
for central air conditioners and heat pumps, the Air-Conditioning, Heating and
Refrigeration Institute (AHRI) called on the U.S. Department of Energy to be
more "thorough and vigorous" during its next rulemaking process that
began earlier this month. DOE will use the rulemaking process to determine
whether the minimum efficiency standards, which were increased in 2006, should
be revised again by 2016.
AHRI's Vice President for Regulatory
Policy and Research,
Karim Amrane, testified June 12 during
a public meeting in Washington, D.C., that DOE severely underestimated the cost
increase from a 10 SEER to a 13 SEER system.
Amrane called on the DOE to perform
thorough analyses in three areas:
- Cost increases associated
with higher efficiency standards
- Potential cost impact from
an HFC cap as part of climate change policy
- Feasibility of
various enforcement mechanisms for possible regional efficiency standards
"DOE
needs to step back and review past analyses to understand where improvements
need to be made," Amrane announced. He added that there is evidence the DOE's
predicted incremental cost of $335 between a 10 SEER and a 13 SEER split air
conditioner was severely underestimated and he cited a 9 percent drop in
equipment sales since the 13 SEER mandate took effect. This fact, combined with
an increase in parts sales and room air conditioners, he said is evidence that
the new standard is not economically justified for many consumers. He also said
the energy savings estimated by DOE were probably overstated as well.
Amrane also asked the energy department
to "carefully study the impact of climate change legislation on the
availability and price of HFC refrigerants." He said there is a real
possibility prices will skyrocket and not enough refrigerant will be available
to meet the new energy conservation standards.
Amrane explained that higher efficiency
products require more refrigerant charge because they have larger evaporators
and condensers. He added that despite this fact, dominate in the U.S. Senate is
a climate change bill that would set an HFC cap for 2016 at 39 percent below
estimated industry demand.
In addition, Amrane told the DOE
that if regional standards are adopted, either as part of the current
rulemaking process or another process, they will present unique enforcement
challenges. He said any regional standard above the base national standard will
require enforcement of product distribution and installation. He stressed that
a successful enforcement plan would require the participation of all
stakeholders, including manufacturers, distributors, contractors and code
officials.
