By Mark Riso Director of Government Relations PHCC National Association
T
U.S. DOE Proposes Efficiency Changes
he U.S. Department of Energy (DOE) has an obligation to periodically review efficiency standards for a wide variety of products. Currently DOE is considering several proposals in the HVAC arena that would conserve fuel, reduce carbon emissions and ultimately save consumers operating dollars. Any adopted changes would not be implemented for approximately five years to allow industry time to make adjustments. PHCC is participating with industry stakeholders to understand the implications of the proposal. Meetings have been held by the U.S. Department of Energy (DOE) trying to explain the proposed new efficiency standard for residential non-weatherized gas furnace products to be effective in 2021. DOE has changed its previous position intending to promote regional standards for gas furnaces and now is proposing a single national standard efficiency level of 92%. PHCC along with other stakeholders expressed concern for the discontinuation of the 80% efficient class of gas furnace equipment. Many noted there is significant installed product in this class of equipment, replacement of which would face increased costs related to higher efficiency equipment and also additional changes to the venting systems. Many of these systems are in residences of economically challenged families, families who would face some difficult decisions for their heating systems. In a second proposed rulemaking, DOE has proposed increasing minimum efficiency standards for residential boilers, as shown in the table at right. The process through which these changes evolve is at the NOPR (Notice of Proposed Rulemaking) [ 18 ]
Maryland PHCC Contractor | Summer 2015
stage. In this stage, DOE puts forth ideas for industry consideration, but is not constrained by their basic proposals. Discussions with stakeholders can effect changes in the proposal or may reinforce the process of development. It is important at this phase to listen and understand the proposal, its underpinning logic, and supporting data. By careful vetting of the DOE program, stakeholders are able to support a proposal or make statistically valid challenges to the process. Bear in mind, DOE has the ability to make changes in the proposal; stakeholder challenges could be resolved by DOE during this phase. These Efficiency Standard changes, along with others in the DOE system, provide positive benefits for consumers. There are however, some drawbacks that frequently accompany changes to the status quo. Consumers and stakeholders have ample opportunity to provide suggested changes during the rulemaking process. PHCC will be filing comments and will communicate both the positives and negatives to members to allow grass roots feedback to the Agency. PHCC supports promoting high efficiency products to consumers through a transparent process that must be a result of a fair and equitable energy efficiency standard.