Friday, December 2, 2011

DOE outlines possible enforcement options for Regional Standards

DOE outlines possible enforcement options
This morning the Department of Energy released a Framework document regarding enforcement of the newly installed regional standards. This document is intended to provide stakeholders with an idea of what the DOE may have in mind and allow for discussion, before an official enforcement proposal is released in January.

The DOE has stated that the effective dates (May 1, 2013 for furnaces and January 1, 2015 for air-conditioners) are installation bans, therefore eliminating "Grandfather" provisions that have marked previous standards increases and leaving distributors to liquidate inventory before the effective date or risk it being stranded.

Additionally, the DOE has laid out three different enforcement approaches that they are considering. All three approaches put unprecedented burdens on distributors and clearly represent why HARDI opposed this regulation in the first place.

  • The "least invasive" proposal would mandate distributors to inform the purchaser of equipment of the regional standards and require a signature from the contractor which would indicate they understand the regional standards. This letter would then be kept under file by distributors.
  • A second option would require the distributor to track serial numbers of equipment sold to contractors and maintain those records in the event of an audit by the federal government.
  • The most aggressive proposal would require distributors to track serial number, installer, and installation location information for units sold and to submit the information on a regular basis or face penalty.
HARDI urges all members to read the DOE's Framework document and contact Jon Melchi with your thoughts and recommendations.

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