Saturday, January 21, 2017

Deja Vieux

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.

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.

To read more about AHRIs position on the HFC phasedown, read this NEWS article

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