We have been here before. An outgoing administration is promulgating lots of final rulings in their last gasp and an incoming administration is working hard to undo those rulings. We the regulated, are caught in the middle.
SEER 13 SEER 12 SEER 13
Just before January 20, 2001 when Bill Clinton left office, the Department of Energy upped the minimum SEER from 10 to 13. The change was to take effect in 2006. ARI objected and the Bush administration agreed to drop the minimum from 13 to 12. The DOE published the new 12 SEER standard in May 2002. Several states as well as national environmental and consumer groups successfully sued. On Jan. 13, 2004, the U.S. Appeals Court for the 2nd Circuit, based in New York, ruled that the DOE did not follow "proper procedures" when it adopted its 12 SEER standard in May 2002. The more stringent 13 SEER standard was reinstated.
This is an oversimplification of the actors and events, but tell the basic story. Instead of having from 2001 until 2006 to reinvent their product line, manufacturers had only from May of 2004 until January of 2006 because of the regulation wars. In retrospect, it would have been far easier to shoot for the 13 SEER target from the beginning and have several more years to accomplish it.
HFC Phasedown
Like a case of deja vieux, the outgoing Obama administration just signed a Global Warming amendment to the Montreal Protocol this past October and the incoming Trump administration wants to scrap all Global Warming initiatives. However, AHRI is not beating the drums to slow down or scrap the HFC reductions. Instead they are saying that what they really want is regulatory consistency and certainty. In other words, they don’t want to relive the 2001 – 2006 SEER wars.
Nothing is Constant but Change
There are mid-term elections in two years, and the ruling party almost always take a beating, meaning the senate may change hands in two years. If this election has taught us anything, it is that we cannot know for certain who will be heading up the government in four years. In eight years we are guaranteed to have a change at the top. It takes years to develop and test new products, and the last thing any manufacturer wants is to have the design parameters altered drastically and capriciously based on the latest election. Even if the challenges are steep, they can be met with a reasonable time for development if you don’t keep moving the goal posts.
To read more about the history of the SEER wars read this excellent article in the NEWS.
http://www.achrnews.com/articles/97373-how-we-got-to-13-seer
To read more about AHRIs position on the HFC phasedown, read this NEWS article
http://www.achrnews.com/articles/134252-kigali-agreement-creates-orderly-phasedown-of-hfcs
Showing posts with label DOE. Show all posts
Showing posts with label DOE. Show all posts
Saturday, January 21, 2017
Saturday, December 3, 2016
Cranking Out The Rules
With only weeks left in the Obama administration, federal agencies such as the Energy Efficiency and Renewable Energy Office
(EERE) are finishing up work on a number of initiatives and publishing final
rulings. Who are the EERE? They are a subset of the Department of Energy (DOE). These
rulings have an impact on the HVACR industry. While the rulings do not have a
direct effect on technicians in the field, they have a big effect on HVACR
manufacturers. Indirectly they will affect us as manufacturers respond to the
directives. Most of the rulings have to do with how different equipment is
tested by the manufacturer, and in some cases, what equipment is covered. Here is a list of recent rulings with links
for more information.
12/02/2016 DOE Issues a Notice of Final Rule Pertaining to
Test Procedures for Walk-in Coolers and Walk-in Freezers
12/01/2016 DOE Issues a Notice of Final Rule Pertaining to
Test Procedures for Compressors
11/30/2016 DOE Issues a Final Rule Pertaining to Test
Procedures for Central Air Conditioners and Heat Pumps
11/21/2016 DOE Issues a Comment Period Extension Pertaining
to Energy Conservation Standards for Residential Furnaces
11/15/2016 DOE
Publishes a Final Determination of Compressors as Covered Equipment
11/10/2016 DOE Publishes a Final Rule Pertaining to Test
Procedures for Commercial Packaged Boilers
10/07/2016 DOE Issues a Final Determination Pertaining to
Energy Conservation Standards for Direct Heating Equipment
10/04/2016 DOE Issues a Direct Final Rule Pertaining to
Energy Conservation Standards for Miscellaneous Refrigeration Products
Friday, July 29, 2016
Regional Efficiency Reporting Rules
Right in the middle of the hottest and busiest summer in years the government is helping us by adding some more regulations and paperwork. The good news is that you probably already keep the records they are requiring. The Energy Efficiency and Renewable Energy Office (EERE) has just issued their final ruling on enforcement of the regional energy efficiency standards. The ruling requires equipment manufacturers, distributors, and contractors to keep records of the equipment they sell. It also requires that split systems be matched, and makes a distinction between uncased coils used as part of a complete system installation and those used as a replacement part.
The law on which this ruling is based is not new. It is Title III of the Energy Policy and Conservation Act of 1975. This specific ruling is new. It is a follow-up to the Regional Efficiency Standards. Although the regional efficiency standards have in been in place now since January 1, 2015, the details regarding enforcement are new.
What Equipment is covered by this ruling?
The Energy Policy and Conservation Act defines a “central air conditioner” as a “product . . . which . . . is a heat pump or a cooling only unit” and refers to all central air conditioners as one “product.” So when they say air conditioner, they are including heat pumps. Split system air conditioning and heat pump condensing units, cased coils, uncased coils installed as part of a new installation, packaged air conditioning and heat pump systems are all covered by this ruling. NOT covered by this ruling are furnaces and uncased coils installed as replacement parts.
Who Must Keep Records?
Equipment manufacturers, distributors, and contractors must all keep records. However, the information you are required to keep depends upon which of these you are and what specific equipment is involved.
For every condensing unit, indoor unit and packaged unit installation, contractors must keep the following information for four years:
I expect most contractors already do record all the items on this list. Most manufacturers will want this information for warranty purposes. If you plan to service the equipment for the customer, you certainly want to know things like the model number, serial number, location, and date of installation. Since any properly installed system should last much longer than four years, keeping those records for at least four years makes perfect sense. Furnaces are not covered by this ruling. However, as long as you are keeping detailed information on the coil sitting on top of the furnace, why not go ahead and record the furnace information as well?
It is interesting to note that the condensing unit and coil are being listed separately. It is really not correct to say a condensing unit is 14 SEER, because it needs a matching coil. Since different matches yield different results, a single condensing unit can produce a range of efficiencies. To address this issue, the lowest rating point using the condensing unit manufacturer’s own indoor coil is what determines where a split system condensing unit may be used. So if a condensing unit has a rating of 13 SEER with one coil and 14 SEER with another coil, it will be considered 13 SEER unit. When using a third party indoor coil, the coil must be matched to the condenser. However, a third party coil may not be used to increase a condenser’s rating point above the manufacturer rating. For the purposes of meeting the minimum efficiency for your area, you may not use one manufacturer’s coil matched to another manufacturer’s condenser to obtain a rating higher than the condenser manufacturer lists. Obviously, this CAN be done, but it won’t qualify the unit as a 14 SEER unit if the condenser manufacturer lists a 13 SEER coil match for that unit.
Records must be kept for all cased coils. Records on uncased coils may or may not be required depending upon their use. If an uncased coil is a replacement part, you do not have to keep records on it. An example would be replacing a leaky indoor coil on an existing system. However, if an uncased coil is used as part of a complete install, then you do have to keep records on that coil. You are not required to keep serial numbers on indoor coils. Many indoor coils do not have a serial number.
If you are looking for an easy way to keep this data, I suggest an Excel spreadsheet. Excel is a commonly used program and many of you may already have it. A spreadsheet does not take up lot of space and you can keep data on several systems on a single spreadsheet. Depending upon the number of systems you install in a month, you could have a spreadsheet for each month, or even one for the entire year.
I have put together a very simple Excel spreadsheet which you might like to use. The data handling functions of Excel allow you to sort and search data by different categories. For example, a search of listings by model number or by address. Here is the link to download the file.
https://drive.google.com/open?id=0B0i1Mw3czgHrMmFwRlR4dzVWR1k
I encourage you to read it for yourself – as government regulations go it is pretty short. Here is a link to the ruling.
http://www.regulations.gov/document?D=EERE-2011-BT-CE-0077-0102
You might also like to read an excellent article by Jen Anesi in "The Air Conditioning, Heating, and Refrigeration News.”
http://www.achrnews.com/articles/132995-new-ac-reporting-rules-coming
The law on which this ruling is based is not new. It is Title III of the Energy Policy and Conservation Act of 1975. This specific ruling is new. It is a follow-up to the Regional Efficiency Standards. Although the regional efficiency standards have in been in place now since January 1, 2015, the details regarding enforcement are new.
What Equipment is covered by this ruling?
The Energy Policy and Conservation Act defines a “central air conditioner” as a “product . . . which . . . is a heat pump or a cooling only unit” and refers to all central air conditioners as one “product.” So when they say air conditioner, they are including heat pumps. Split system air conditioning and heat pump condensing units, cased coils, uncased coils installed as part of a new installation, packaged air conditioning and heat pump systems are all covered by this ruling. NOT covered by this ruling are furnaces and uncased coils installed as replacement parts.
Who Must Keep Records?
Equipment manufacturers, distributors, and contractors must all keep records. However, the information you are required to keep depends upon which of these you are and what specific equipment is involved.
For every condensing unit, indoor unit and packaged unit installation, contractors must keep the following information for four years:
- Manufacturer
- Model Number
- Serial Number (NOT required for indoor units including blower coils, cased coils, and uncased coils installed as part of a new installation)
- Installation Location including the street address, city, state and zip code
- Installation Date
- Party from whom the unit was purchased, including the seller’s name, address and phone#
I expect most contractors already do record all the items on this list. Most manufacturers will want this information for warranty purposes. If you plan to service the equipment for the customer, you certainly want to know things like the model number, serial number, location, and date of installation. Since any properly installed system should last much longer than four years, keeping those records for at least four years makes perfect sense. Furnaces are not covered by this ruling. However, as long as you are keeping detailed information on the coil sitting on top of the furnace, why not go ahead and record the furnace information as well?
It is interesting to note that the condensing unit and coil are being listed separately. It is really not correct to say a condensing unit is 14 SEER, because it needs a matching coil. Since different matches yield different results, a single condensing unit can produce a range of efficiencies. To address this issue, the lowest rating point using the condensing unit manufacturer’s own indoor coil is what determines where a split system condensing unit may be used. So if a condensing unit has a rating of 13 SEER with one coil and 14 SEER with another coil, it will be considered 13 SEER unit. When using a third party indoor coil, the coil must be matched to the condenser. However, a third party coil may not be used to increase a condenser’s rating point above the manufacturer rating. For the purposes of meeting the minimum efficiency for your area, you may not use one manufacturer’s coil matched to another manufacturer’s condenser to obtain a rating higher than the condenser manufacturer lists. Obviously, this CAN be done, but it won’t qualify the unit as a 14 SEER unit if the condenser manufacturer lists a 13 SEER coil match for that unit.
Records must be kept for all cased coils. Records on uncased coils may or may not be required depending upon their use. If an uncased coil is a replacement part, you do not have to keep records on it. An example would be replacing a leaky indoor coil on an existing system. However, if an uncased coil is used as part of a complete install, then you do have to keep records on that coil. You are not required to keep serial numbers on indoor coils. Many indoor coils do not have a serial number.
If you are looking for an easy way to keep this data, I suggest an Excel spreadsheet. Excel is a commonly used program and many of you may already have it. A spreadsheet does not take up lot of space and you can keep data on several systems on a single spreadsheet. Depending upon the number of systems you install in a month, you could have a spreadsheet for each month, or even one for the entire year.
I have put together a very simple Excel spreadsheet which you might like to use. The data handling functions of Excel allow you to sort and search data by different categories. For example, a search of listings by model number or by address. Here is the link to download the file.
https://drive.google.com/open?id=0B0i1Mw3czgHrMmFwRlR4dzVWR1k
I encourage you to read it for yourself – as government regulations go it is pretty short. Here is a link to the ruling.
http://www.regulations.gov/document?D=EERE-2011-BT-CE-0077-0102
You might also like to read an excellent article by Jen Anesi in "The Air Conditioning, Heating, and Refrigeration News.”
http://www.achrnews.com/articles/132995-new-ac-reporting-rules-coming
Thursday, January 8, 2015
New Regional Efficiency Standards Take Effect
In case you missed it, there are now new minimum efficiency
standards for residential air conditioning equipment. As of January 1, 2015 the
long discussed regional air conditioning standards went into effect. They are
called regional standards because the minimum legal efficiency of the equipment
is determined by the region of the country in which it will be installed. For
Northern states, nothing changes – the minimum stays at 13 SEER. For the
southeast, the minimum is increased to 14 SEER. For the southwest, the minimum is a bit more
complicated. The SEER rises to 14, but minimum EERs are also introduced. The
minimum EER for the Southwest is 12.2 for systems less than 45,000 Btuh and
11.7 for systems 45,000 Btuh and greater. So a 13 SEER system that is legal in
Indiana is illegal in Kentucky. A 14 SEER system that is legal in Texas might
not be in Arizona, depending on its EER. Although the minimum efficiencies are
already in effect, the enforcement mechanism has yet to be determined.
It is interesting to note that it is possible for a unit to
have a higher SEER than another unit, but for the lower SEER unit to have a
higher EER. That is the reason for the dual SEER/EER conditions.
Rheem has a good page with a map and a table explaining the
new standards
There is a very informative presentation on the California
Energy Commision’s web site by Steve Kavanaugh explaining the reasoning behind using both SEER and
EER for minimum efficiency standards.
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