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Advocacy is one of the three main functions of the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), and it involves not just promoting the HVACR and water heating industry and the positive impact it has on society, but also working to protect it, along with its customers and the 1.2 million Americans it employs. AHRI represents manufacturers of heating, ventilation, air conditioning, commercial refrigeration, and water heating products. Our 300-plus member companies are divided into 39 product sections, which write standards that support 40 certification programs.
AHRI’s primary advocacy goal is increased Congressional attention toward federal regulatory agencies, which are enacting policies through rulemakings that negatively affect the U.S. manufacturing sector, including our industry. While well-intentioned, these unsubstantiated, unjustified regulations smother innovation, cost small businesses and consumers more for products they need, and stifle jobs that the economy depends on, all while saving far less energy than intended. Congressional oversight can help balance legislative intent with regulatory outcome.
The latest rule from the Department of Energy, setting new efficiency standards for commercial refrigerators, is just one example of regulatory overreach. It enacts a minimum efficiency level for some product categories that is more stringent even than the current Energy Star level. The provisions of this rule run contrary to the normal standards-setting approach, which seeks to gradually raise the minimum efficiency level to minimize the burden on manufacturers and consumers. As a result, more expensive technology is needed—or still needs to be invented—to meet the requirement that takes effect just three years from now, which will mean more costly refrigeration units for food and beverage retailers, higher prices for consumers of those items, and a significant negative impact on small manufacturing businesses that are unable to manufacture equipment to such demanding standards. In the end, the new rule is not likely to save nearly as much energy as intended, because it will be cheaper for businesses and consumers to repair their old equipment rather than replace it.
AHRI members support energy efficiency and are not opposed to regulations. The industry has a proud history of innovation that has produced highly efficient, affordable equipment. AHRI also has a proud history of collaborating with government agencies on energy efficiency standards that both accomplish their goals and work in the marketplace.
We believe Congress should serve as a more effective monitor of agency regulatory activity to ensure that the rulemaking process is transparent and substantiated, resulting in economically justified and technologically feasible regulation of the industry.