CEC Considers TXVs for A/C Units
Enter Assembly Bill (AB) 970, which was signed into law on Sept. 6, 2000, much of which is slated to go into effect June 1, 2001.
Proponents of the law hope it provides solutions to the electricity problems facing the state and results in a significant investment in new, environmentally superior electricity generation. In theory, this will in turn help draw significant investments in conservation and demand-side management programs.
Among other things, AB 970 directs the California Energy Commission (CEC) to adopt and implement, within 120 days, updated and cost-effective standards to ensure the maximum feasible reductions in wasteful, uneconomic, inefficient, or unnecessary consumption of electricity.
One of the proposed standards would prescribe an older technology: the use of thermostatic expansion valves (TXVs) on air conditioning units. Other measures would increase minimum efficiency beyond current National Appliance Energy Conservation Act (NAECA) requirements and seal up leaking ducts. CEC intends to act on these proposals this week.
CEC staff has acknowledged that the TXV rule would require the granting of a waiver of federal preemption by the U.S. Depart-ment of Energy (DOE) before it could go into effect. The DOE waiver cannot allow such a rule to go into effect for at least three years after such time as a waiver might be granted.
CEC has already passed a TXV rule on an “emergency” basis in its building code for new construction which, if not dropped by CEC, would also go into effect June 1. It would require the installation of TXVs on less-efficient equipment, or the installation of air conditioning equipment with efficiencies higher than the current federal minimum.
Alternatively, it would require use of an energy budget calculated on the basis of a TXV. CEC intends to further review the building code provision this week to determine whether it should be adopted permanently as of June 1.
The TXV PROVISIONS“Of importance to contractors are the proposal by the CEC to prescribe TXVs on all new and replacement central air conditioners, and the TXV rules in the building code,” said Karim Amrane, director of Public Policy for the Air-Conditioning and Refrigeration Institute (ARI). “ARI understands that the requirement concerning replacement units would apply only if the indoor unit is replaced.”
The CEC argues that there is strong evidence from numerous studies that TXVs could help reduce peak electrical demand, and it held a second workshop in early December 2000 to review the cost-effectiveness analysis and obtain feedback from stakeholders.
ARI legal counsel has reviewed the matter and has concluded that a CEC rule requiring TXVs and the TXV provision in the building code are preempted by the Energy Policy and Conservation Act (EPCA) as amended by the NAECA. Counsel states that they could go into effect only if the DOE grants a waiver of preemption.
ARI is concerned “that a TXV rule, if implemented by the CEC, would set a precedent that violates the NAECA provisions and could lead to far-reaching consequences to the industry through the imposition of other prescriptive actions.”
For these reasons, Amrane said ARI has submitted comments to the CEC opposing TXV requirements. ARI said it is neither in favor of nor against any particular expansion device technology; however, it opposes prescriptive measures or a budget approach that could conflict with NAECA.
Duct Leakage, Radiant BarriersLike Florida did a few years back, California is starting to address the issue of duct leakage in both residential and non-residential buildings.
“Studies show that the ductwork in a typical new home loses between 20% to 30% of the cool air it carries in the summer, causing air conditioners to work harder, wasting electricity, driving up energy bills, and making the home less comfortable,” stated the commission.
Another feature of the new standards, according to the CEC, is the requirement for radiant barriers that reflect heat from the sun in attic spaces, and improved window requirements that will reduce the amount of solar heat that radiates into a home and adds to the air conditioning load.
“Increasing air conditioning use on hot summer afternoons has driven California’s electricity consumption to new highs,” said the CEC. “This could endanger the electricity system and bring the state to the brink of rolling blackouts. In San Diego County, some summer electricity bills increased by as much as 300%.”
Refrigeration, TooRemember the “r” in hvacr? The legislation would also affect the refrigeration sector.
“The CEC is proposing that self-contained commercial refrigerators and freezers with doors — except refrigerated bottled, canned beverage vending machines, refrigerated buffet units, and preparation tables — be tested according to ASHRAE 117-1992, with some additional product temperature conditions,” said Miller.
ARI said it is concerned that the CEC does not understand how these products are used in the field, nor how they are tested by the industry.
“ARI has serious reservations with the proposed energy efficiency standards,” said Miller. “The CEC justifies these levels based on its belief that 75% of the products listed in its database meet the proposed minimum efficiencies. However, ARI questions how the CEC could make such a determination when industry products have not been tested according to the proposed test procedures.”
Higher Seer, Bigger FootprintManufacturers Lennox, Trane, and York were all cited in Miller’s comments to the CEC, saying that the SEER increase — from 10 SEER to 13 SEER — will cause a reduction in performance of central air conditioners and heat pumps “by substantially increasing the size of equipment.
“Lennox stated that increasing standards to 13 SEER will almost double the footprint of units and result in a need to replace the mounting pad with a larger size for applications on grade,” Miller said. “This will make replacement units more costly and also require expensive relocation of the electrical service and refrigerant lines.”
York pointed out that raising the efficiency standards would place great stress on manufactured housing because of limited space for air conditioning units.
Miller stated that the CEC would be doing many things wrong by increasing efficiency levels as proposed:
According to Miller, and using the cost multipliers and installation costs determined by the DOE, the equipment cost would change dramatically (see Table 1). If this is accurate, Miller contests that the “incremental cost of split air conditioners at the proposed 13 SEER is $452, not $292 as claimed by the CEC,” based on DOE data included in its technical support documents.
ARI believes that even if the CEC uses its numbers, an energy saving amount of $355, “The state of California will, in fact, incur a net annual loss of $19,885,000, clearly indicating that the proposed standards are not economically justified.”
There are many people in the country that do not have air conditioning, and some die from the deprivation every year. With the increase of the SEER, according to Miller, the cost will go up for air conditioners, and thus prevent even more of those who need air conditioning from getting it.
“The U.S. Census indicates that 16% of Californians are below the poverty line. There should be no more stories about elderly Americans dying from heatstroke because they cannot afford to purchase air conditioning products,” she said.
Where It Stands NOWEarly this year, the CEC adopted emergency standards for energy efficiency in new buildings that it believes will cut the state’s energy use by 200 MW annually. According to CEC, this equates to enough electricity to power 200,000 average-sized California homes. The decision was unanimous (4-0).
According to energy commissioner Robert Pernell, presiding member of the Efficiency Com-mittee, the vote “illustrates how the Energy Commission is attacking the state’s electricity problems in two ways: by decreasing the demand for power through energy efficiency, even as it increases the amount of electricity made available by new power plants.”
The CEC said that the changes have the support of utilities, window manufacturers, the California Building Industry Association, and the National Resources Defense Council.
According to Ed Dooley, vice president of Communications for ARI, a public hearing took place on Jan. 19. Several manufacturers were on hand to voice their concerns.
“We have to make our point known that we do not support the TXV ruling and the efficiency levels,” said Dooley. “We want to urge them to make alterations to adopt a 12-SEER level that the industry can support.”
Sidebar: What to Tell Customers About Conserving EnergyATLANTA, GA — The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) said there are actions the public can take in reducing energy. By giving consumers this information, ASHRAE believes contractors can further position themselves as valuable consultants.
Some of the actions include:
Publication date: 02/05/2001