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
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.