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The two main issues under consideration are how the agencies will enforce the new regional standards and what changes are necessary to the labeling of HVAC equipment to avoid distributor, contractor, and consumer confusion about the new rules.
ACCA noted that regional standards will set new liabilities and responsibilities on HVAC contractors to install equipment that meets minimum efficiency levels for a given state. There are likely to be new paperwork and filing requirements for contractors, along with the potential for fines for violations of the rules.
DOE is proposing three enforcement approaches with increasing levels of compliance through record keeping and/or the reporting of equipment installation location information.
Under Approach 1, contractors would be required to install HVAC equipment in the appropriate region.
Under Approach 2, contractors would be required to install HVAC equipment in the appropriate region, and maintain records and paperwork about each installation.
Under Approach 3, contractors would be required to install HVAC equipment in the appropriate region, maintain records and paperwork about each installation, and be required to provide their distributors with model number, rated efficiency, serial number, and installation address for each installation. Distributors would report the model number, efficiency, serial number, and installation zip code (not address) to DOE.
The FTC rulemaking on new energy labeling requirements for residential furnaces, central air conditioners, and heat pumps is designed to help consumers and businesses install equipment appropriate for their location under the new regional efficiency standards. The FTC's Appliance Labeling Rule currently requires yellow EnergyGuide labels for heating and cooling equipment to disclose the product's efficiency rating and a comparison of the highest and lowest ratings for all similar models.
The FTC wants to know how best to develop consumer and industry disclosures regarding the new standards for residential furnaces, central air conditioners, and heat pumps, including possible revisions to the current EnergyGuide label.
Both agencies will take comments and develop proposed rules that will be open to public comment. The rulemaking process must conclude by mid-January 2013.
Publication date: 12/14/2011