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 (DOE) 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 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 said. He added that there
is evidence 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 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.
