Tuesday, October 18, 2011

HARDI voices opposition to Regional Standards

HARDI files comments in opposition of Regional Standards/ Efficiency Standards Increase

On Monday HARDI filed comments in opposition to a Department of Energy (DOE) Direct Final Rule which would regionalize air conditioners and furnaces as well as increasing efficiency standards for those products in certain regions. The Direct Final Rule came as a result of a pact negotiated by equipment manufacturers and energy efficiency advocates and excluded the input of HVAC distributors and contractors. HARDI has asked the DOE to withdraw the direct final rule and precede with the traditional rulemaking (NOPR) process which would allow for more analysis and stakeholder input.

HARDI indicated in previous comments to DOE that we would only be able to offer support to the proposed rule if the planned increases in efficiency standards were economically justifiable. HARDI maintains that the nation’s economic climate, including an unprecedented drop in new home construction, coupled with the substantial decline in unitary sales of both air conditioners and furnaces since the last national standards and a reduction in consumer purchasing power do not make the proposed rule viable on an economic level.

Additionally, HARDI has great concerns about the unknown costs that will come with compliance and enforcement of the proposed rule. HARDI believes that it is impossible for the DOE to fully assess the economic impact of the rule without first finalizing an enforcement plan. HARDI fears that the cost and responsibility associated with compliance and enforcement will fall far from the manufacturers who negotiated the agreement, and will land squarely upon the many small businesses in both the HVAC distribution and contract installation industry. HARDI has asked the DOE withdraw the direct final rule and move the rule to a NOPR with a combined, or concurrent, enforcement rulemaking.

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