Matt Lattanzi Regional Standards/Regulatory

Update

Regional Standards

Regional Standard Map

HDD < 5000 South

Application Federal Minimum

Split System AC 14 SEER

Split System HP 14 SEER/8.2 HSPF

Package AC 14 SEER

Package HP 14 SEER/8.0 HSPF

Weatherized Gas Furnace (Gas Pack) 14 SEER/81% AFUE

Non-Weatherized Gas Furnace 80% AFUE

Oil Furnaces (non-weatherized) 83% AFUE

HDD ≥ 5000 North

Application Federal Minimum

Split System AC 13 SEER

Split System HP 14 SEER/8.2 HSPF

Package AC 14 SEER

Package HP 14 SEER/8.0 HSPF

Weatherized Gas Furnace (Gas Pack) 14 SEER/81% AFUE

Non-Weatherized Gas Furnace 90% AFUE

Oil Furnaces (non-weatherized) 83% AFUE

Southwest

Application Federal Minimum

Split System AC 14 SEER/12.2 EER < 45,000 BTU/hr14 SEER/11.7 EER ≥ 45,000 BTU/Hr

Split System HP 14 SEER/8.2 HSPF

Package AC 14 SEER/11.0 EER

Package HP 14 SEER/8.0 HSPF

Weatherized Gas Furnace (Gas Pack) 14 SEER/81% AFUE

Non-Weatherized Gas Furnace 80% AFUE

Oil Furnaces (non-weatherized) 83% AFUE

Observations

• National Heat Pump Standard– Split HP: 14 SEER/8.2 HSPF– Package HP: 14 SEER/8.0 HSPF

• National Oil Furnace Standard– 83% AFUE

• National Weatherized Furnace Standard (Gas Packs)– 14 SEER/81% AFUE

Enforcement

Regional Standards (DOE Guidance – coil only ratings)

• DOE interprets for the regional standard to require that the least efficient rating combination for a specified model of condensing unit must be 14 SEER where 14 SEER is the regional standard. Any model that has a certified combination below the regional standard cannot be installed in the region.

Regional Standards (DOE Guidance – coil only ratings)

• In other words:

– No 13 SEER AC + VSB for the south or southwestern region

– No 13 SEER dry R22 split system AC for the south or southwestern regions.

Inventory

• Grace Period if manufacture date prior to 1/1/15.– Affected Units

• 13 SEER Split ACs (including dry R22)• 13 SEER Package ACs

• Must be installed by 7/1/16

Inventory

• Manufacture Date prior to 1/1/2015• Can be sold/installed indefinitely

– Affected Units• 13 SEER Split HPs• 13 SEER HPs

New Energy Guide Labels

New Energy Guide Labels

Regional Standards (Enforcement)

• Enforcement is a new rulemaking• DOE working group developed a recommendation for enforcement.

– Still has to be codified by DOE

• Enforcement Includes:– Reporting– Records Retention– New Labels– Violation– Remediation

Reporting(whistle blowing)

• DOE will accept complaints in Enforcement inbox– EnergyEfficiencyEnforcement@hq.doe.gov

• DOE will set up voicemail box for call-in complaints

• Complainant will have confidentiality to maximum extent authorized by law

• DOE will look into all credible complaints

Records Retention (Contractors – 48 months)

• Scope: applies to installations in the South and Southwest• Split-system central air conditioner:

– outdoor condensing unit: manufacturer, model and serial number – indoor coil or air handler: manufacturer and model number

• Single package air conditioner: – manufacturer, model and serial number

• For all such units: – location of the installation (including street address, city, state, and zip code)– date of the installation; and– party from whom the unit was purchased, including company or individual’s

name, full address and phone number• Implementation Date: 30 days after the regulation is published.

Records Retention (Distributors – 54 months)

• Split-system central air conditioner: – outdoor condensing unit: manufacturer, model and serial number

• Single package: manufacturer, model and serial number• For all such units:

– date unit was purchased from manufacturer– party from whom the unit was purchased, including company or

individual’s name, full address and phone number– date unit was sold to dealer/contractor– party to whom the unit was sold, including company or individual’s

name, full address and phone number– if delivered, delivery address

• Implementation date: – November 30, 2015

Records Retention (Manufacturers – 60 months)

• Split-system central air conditioner: – outdoor condensing unit: model and serial number – indoor coil or air handler: model number

• Single package air conditioner: model and serial number• For all such units:

– date of manufacture; – date of sale; and– party to whom the unit was sold, including company or individual’s

name, full address and phone number• Implementation Date: 30 days after the regulation is published.

Manufacturer Labels

• Manufacturers will add label to outdoor unit– Near or as part of current nameplate– Ruggedized to withstand elements

• States “Install Prohibited in [pertinent regions]”– Southwest or South and Southwest

• To be implemented by March 1, 2015– Also target date for AHRI certification program

• Below is a new box label.

Violation

Distributor:– knowingly sell a product to a contractor or dealer with knowledge that the

entity will sell and/or install the product in violation of any regional standard applicable to the product

– knowingly sell a product to a contractor or dealer with knowledge that the entity routinely violates any regional standard applicable to the product

Contractor/Dealer:– knowingly sell to and/or install for an end user a central air conditioner subject

to regional standards with the knowledge that such product shall be installed in violation of any regional standard applicable to the product

Routine Violator

• DOE will issue Notice of Finding of Routine Violation if determined to be routine violator

– DOE will post your company name on their enforcement website

– DOE will blast e-mail your company name to distribution indicating you are a routine violator of the standard and they are prohibited from selling all DOE covered products to your company.

• This is serious but it’s not the end of the world. You can remediate.

Remediation

• Sole method is replacement of noncompliant unit– A party may remediate by replacement of noncompliant units or

demonstrate to the Department’s satisfaction the attempted replacement of all noncompliant units

– Remediation is at cost to party in violation• Must provide DOE serial number of old and new unit • DOE will provide these numbers to the manufacturer(s) and

distributor(s)– check against warranty or other replacement claims

• If remediation is verified, the violation will not count towards finding of “routine violator” unless repeated

• And, DOE will issue Notice of Remediation

Enforcement Summary

Manufacturer Independent Distributor

Contractor/Dealer

Subject to civil penalties based upon committing a prohibited act

Yes No No

Can be labeled a routine violator

No Yes Yes

Can remediate to get off routine violator list

N/A Yes Yes

Right to appeal finding of Routine Violation

N/A Yes Yes

Record retention 60 months 54 months 48 monthsRecord retention start date 30 days after Final

RuleNov. 30, 2015 30 days after Final

Rule

Regulatory and Legislative Activity

Regulatory (finalized rulemakings)

• Furnace Fan Efficiency rule– Establishes FER rating (new metric)– The rule is finalized with implementation scheduled for furnaces manufactured

after 7/1/2019– Effectively eliminates all PSC motor furnaces and possibly some constant torque

ECM furnaces (from competitors)

• 3 phase <65,000 BTU/Hr– PACs: 14 SEER– PHPs: 14 SEER, 8.0 HSPF– SACs: stay at 13 SEER– SHPs: 14 SEER, 8.2 HSPF– Effective for products manufactured after 1/1/2017

Energy Star (effective 9/15/2015)

Regulatory (proposed rulemakings)

• Regional Standard Enforcement– Framework developed by ASRAC working group– DOE is late - the finalized rule should have been published months ago

• Residential Furnaces– DOE has issued a NOPR– 92% AFUE nationwide, effective in 2021

• Includes off-mode requirement (impacts our modulating furnace)– Comment period ends at the end of July– Gas organizations strongly oppose (AGA, APGA)– Currently being negotiated between gas organizations, AHRI, ACCA, HARDI, and advocates

• Trying to avoid litigation

Regulatory (proposed rulemakings)

• Unitary large equipment– DOE has issued a NOPR– Effective in 2018– Establishes an IEER standard (new metric)– Finalized In June through ASRAC process

• 2 phases: phase 1 is effective 1/1/2018, phase 2 is effective 1/1/2023.• Phase 1 aligns with ASHRAE 90.1-2013• Phase 2 is 15+% above ASHRAE 90.1-2013

Regulatory (proposed rulemakings)

• Central air conditioners and heat pumps

– Rumor is DOE will issue a NOPR this summer– Industry would prefer to negotiate through ASRAC process

• ASRAC committee is being formed– Also rumored to be as much as 16 SEER with stand by requirements– Stand by requirement effects heat pump crank case heaters– Test procedure is also being re-engineered with this rulemaking

Legislative Activity

• Tennessee and Connecticut state legislatures considering laws that eliminate the practice of registering home appliance to increase warranty terms– Similar to the present law in California– Failed for second year in a row in Tennessee– Passed in first step in Connecticut but still has a long way to go

California Furnaces

• No product available from any manufacturer• Mitigation fees apply: $200 for condensing, $150.00 for non-

condensing• Non-compliant product must be manufactured to and shipped

to the district prior to the compliance date and must be installed within 300 days of the compliance date.

THANK YOU

QUESTIONS