A Glimpse Into the Challenges of Regional Standards

The US Dept. of Energy has started its re-review of the federal energy conservation standards for residential gas furnaces, which now includes authority to establish regional standards, by issuing this Rulemaking Analysis Plan. In it, DOE devotes a section to consider how regionalized efficiency standards could be enforced. Below are DOE's eight initial regional standards enforcement considerations which HARDI is working with AHRI and ACCA to respond to:

1. appropriate modifications to appliance labels to indicate in which regions of the country specific products are allowed to be installed;
2. requirements that marketing literature for systems clearly indicate in which regions a product could be legally installed;
3. encouraging state and local entities to adopt these regional standards in building codes and to provide reference to the required minimum efficiencies in required mechanical or electrical permits;
4. encouraging states who have regional appliance standards to adopt and codify the appropriate regional standards enacted by DOE;
5. providing that installations that don’t meet regional standards could result in installers being subject to fines for each occurrence;
6. requirements to certify compliance of installations through warranty registration or other registration means;
7. an informational program so that consumers are made aware of any regional standards, what to look for in purchasing products, and what implications there would be for improper installation; and
8. competitively driven enforcement where manufacturers/distributors/contractors report
   other manufacturers/distributors/contractors whose actions result in installations not in
   compliance with Federal standards.