EPA Proposes NEW Rules Change

I am a little late getting this out. On October 1, 2018, the EPA proposed a rules change that would effectively wipe out all regulations on non-ozone depleting refrigerants.

Really, the only ozone depleting refrigerant that is widely in service now is R-22, which will be pretty much extinct in a few years. For all of today’s refrigerants, such as HFCs and HFOs, this rule change would mean anyone could purchase refrigerant, no certification would be required to handle refrigerant, no refrigerant recovery would be required, no mandatory leak checks, pretty much no regulations. This would put technicians following best industry practices at an economic disadvantage compared to folks who don’t both purchasing things like recovery machines. It would open up the path for Home Depot and Lowes to sell systems to the public, since purchasers would no longer be required to be certified. I believe it would lead to more mangled equipment, as well as mangled DIY folks who watched a You-Tube video on how to change their own compressor. I urge you to write in to the EPA and tell them that you want to keep the current regulations, passed on November 18, 2016. All comments must be received by November 15, 2018.

Here is a link to the full text of the proposed rule changes

https://www.federalregister.gov/documents/2018/10/01/2018-21084/protection-of-stratospheric-ozone-revisions-to-the-refrigerant-management-programs-extension-to#addresses

Here are the instructions for submitting a comment

Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2017-0629, at www.regulations.gov. You will need to copy and paste the Docket ID 

Appliance Energy Efficiency Standards

The Federal Department of Energy, DOE, has issued a direct final ruling making on furnace and air conditioner efficiency. The regional efficiency standards ruling went into effect October 25. The country is broken into three regions: North, Southeast, and Southwest regions. A map can be seen at MAP. Read more about the ruling at RULING.

In a nutshell: in the Northern region furnace efficiency will increase while heat pump and air conditioning efficiency will remain the same; in the Southeastern and Southwestern regions furnace efficiency will remain the same while heat pump and air conditioning efficiency will increase.

The table below listing the changes comes directly from the final ruling.

Table I.1 Amended Energy Conservation Standards for Furnace, Central Air Conditioner, and Heat Pump Energy Efficiency

Residential Furnaces*
Product Class	National Standards		Northern Region** Standards
Non-weatherized gas	AFUE = 80%		AFUE = 90%
Mobile home gas	AFUE = 80%		AFUE = 90%
Non-weatherized oil-fired	AFUE = 83%		AFUE = 83%
Weatherized gas	AFUE = 81%		AFUE = 81%
Mobile home oil-fired‡‡	AFUE = 75%		AFUE = 75%
Weatherized oil-fired‡‡	AFUE = 78%		AFUE = 78%
Electric‡‡	AFUE = 78%		AFUE = 78%
Central Air Conditioners and Heat Pumps†
Product Class	National Standards	Southeastern Region†† Standards		Southwestern Region‡ Standards
Split-system air conditioners	SEER = 13	SEER = 14		SEER = 14 EER = 12.2 (for units with a rated cooling capacity less than 45,000 Btu/h) EER = 11.7 (for units with a rated cooling capacity equal to or greater than 45,000 Btu/h)
Split-system heat pumps	SEER = 14 HSPF = 8.2	SEER = 14 HSPF = 8.2		SEER = 14 HSPF = 8.2
Single-package air conditioners‡‡	SEER = 14	SEER = 14		SEER = 14 EER = 11.0
Single-package heat pumps	SEER = 14 HSPF = 8.0	SEER = 14 HSPF = 8.0		SEER = 14 HSPF = 8.0
Small-duct, high-velocity systems	SEER = 13 HSPF = 7.7	SEER = 13 HSPF = 7.7		SEER = 13 HSPF = 7.7
Space-constrained products – air conditioners‡‡	SEER = 12	SEER = 12		SEER = 12
Space-constrained products – heat pumps‡‡	SEER = 12 HSPF = 7.4	SEER = 12 HSPF = 7.4		SEER = 12 HSPF = 7.4

The increased standards will be phased in over a period of years. Compliance with the standards in the direct final rule will be required on May 1, 2013 for non-weatherized furnaces and on January 1, 2015 for weatherized furnaces and central air conditioners and heat pumps. Industry reaction has been split. AHRI helped to develop the standards and supports them. They want to avoid the confusion and cost that was associated with the 13 SEER efficiency change that gave the industry very little time to prepare. AHRI also points to the Canadian experience when they mandated 90% . Their sister organization, HRAI, has stated that there were very few problems with Canada’s implementation of 90% standards. Read the AHRI position at LETTER. 

ACCA opposes the standards, especially the 90% furnace mandate, concerned that the extra cost will drive customers to illegal contractors, who feel no compulsion to follow the rules and will cheerfully install equipment that legitimate contractors are not allowed to offer. read ACCA position at ACCA. 

HARDI also opposes the regional standards, citing the difficulty this will make for distributors who service two or more regions. Read HARDI position at HARDI. ACCA and HARDI also cite that there is currently no enforcement mechanism – no DOE police. Again, the problem is that contractors who don’t abide by the ruling achieve a competitive advantage over contractors who do. Regardless of how you feel about the ruling, this is now the law, and all of us in the HVACR industry should prepare ourselves. As far as the DOE police – be careful what you wish for!