Citing poor cost predictions made during past rulemakings for central air conditioners and heat pumps, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), Arlington, VA called on the U.S. Department of Energy (DOE) to be more "thorough and vigorous" during its next rulemaking process that began earlier this month.

DOE will use the rulemaking process to determine whether the minimum efficiency standards, which were increased in 2006, should be revised again by 2016.

AHRI's Vice President for Regulatory Policy and Research Karim Amrane testified June 12, during a public meeting in Washington, D.C., that DOE severely underestimated the cost increase from a 10 SEER to a 13 SEER system.

Amrane called on DOE to perform thorough analyses in three areas: • Cost increases associated with higher efficiency standards
• Potential cost impact from an HFC cap as part of climate change policy
• Feasibility of various enforcement mechanisms for possible regional efficiency standards
"DOE needs to step back and review past analyses to understand where improvements need to be made," Amrane said. He added that there is evidence DOE's predicted incremental cost of $335 between a 10 SEER and a 13 SEER split air conditioner was severely underestimated and he cited a 9 percent drop in equipment sales since the 13 SEER mandate took effect. This fact, combined with an increase in parts sales and room air conditioners, he said is evidence that the new standard is not economically justified for many consumers. He also said the energy savings estimated by DOE were probably overstated as well.

Amrane also asked the energy department to "carefully study the impact of climate change legislation on the availability and price of HFC refrigerants." He said there is a real possibility prices will skyrocket and not enough refrigerant will be available to meet the new energy conservation standards. Amrane explained that higher efficiency products require more refrigerant charge because they have larger evaporators and condensers. He added that despite this fact, dominate in the U.S. Senate is a climate change bill that would set an HFC cap for 2016 at 39 percent below estimated industry demand.

In addition, Amrane told DOE that if regional standards are adopted, either as part of the current rulemaking process or another process, they will present unique enforcement challenges. He said any regional standard above the base national standard will require enforcement of product distribution and installation. He stressed that a successful enforcement plan would require the participation of all stakeholders, including manufacturers, distributors, contractors and code officials.