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ACCA Reacts to California Utility Proposal in Response to Title 24

April 14, 2008
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ARLINGTON, Va. - The Air Conditioning Contractors of America (ACCA) provided an in-depth response to a proposed “California Energy Efficiency Strategic Plan.” The strategic plan was proposed by the California Investor Owned Utilities, which includes Pacific Gas & Electric, San Diego Gas and Electric, Southern California Edison, and Southern California Gas. The plan came about due to dissatisfaction with California’s Title 24 energy code verification plan on the part of the California Public Utilities Commission, and followed a series of stakeholder meetings around the state in which ACCA participated representing California contractors.

While generally supportive of the goals of the strategic plan, ACCA offered several insights into the practical realities of the HVACR marketplace and urged the utilities to embrace the national consensus on quality HVACR installation rather than create standards of their own.

Among other suggestions and requests, ACCA asked California to embrace and incorporate training and education efforts of the HVACR industry in its plan, including baseline contractor training, contractor technician and sales staff training, code official training, and consumer education. It was also concerned that any new requirements had to have consistent, fair, and strong enforcement provisions in place in order to insulate good businesses from competitive disadvantages caused by those who chose not to follow the process.

The association also noted that the plan did not address the fundamental issue of the need to strengthen California’s contractor licensing laws to require continuing education and license reviews. “While the plan did not specifically state a desire for the state to develop its own standards and equipment specifications, it alludes to it,” said ACCA. “We strongly urged the state to avoid creating its own standards and instead leverage existing national movements within the HVACR industry to improve energy efficiency and contractor quality.”

ACCA’s comments were supported by letters from HVACR organizations, including the Air-Conditioning, Heating and Refrigeration Institute (AHRI); Heating, Airconditioning & Refrigeration Distributors International (HARDI); Indoor Air Quality Association (IAQA); National Air Filtration Association (NAFA); North American Technician Excellence (NATE); Plumbing-Heating-Cooling Contractors-National Association (PHCC); and Refrigeration Service Engineers Society (RSES).

For more information, visit www.acca.org/testimony.

Publication date: 04/14/2008

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