“As an industry,” ARI said, “we are not aware of any ozone-reduction process, which by adding it to our equipment, would have a significant impact on the ozone in the Houston-Galveston area or anywhere else in the state. Only one ozone-reduction process is being aggressively marketed, and it appears that it is toxic, and significantly reduces the energy efficiency of our equipment — and, which we believe adds little or no value.”

'Extraordinary action'

The TNRCC is considering what ARI calls the “extraordinary action” of mandating ozone reduction in ambient air by air conditioner condensing coils, despite the fact that air conditioners, unlike automobiles and other items cited in the TNRCC proposal, do not emit pollutants that result in ozone formation.

ARI said that the EPA was offering a “credit” to Texas for using this ozone-conversion process, in such a way that Texas will “become a de facto test bed, or huge field test, for an unproven coating — and causing the citizens of the state of Texas to incur the full cost for such a test.”

ARI said, “We are concerned that after our members have spent literally hundreds of hours reviewing the documents provided by the commission, there is no real evidence that any ozone-reduction process for air conditioning equipment will provide the benefits claimed by a manufacturer.

“Much of the documentation is contradictory and does not even apply to air conditioning equipment, but rather to work done on car radiators. And, under the cover of confidentiality, we have not been able to examine the proposed ozone-reduction process, and the catalyst slurry contained therein, that we fear could be toxic to our workers, technicians that service the equipment in the field, and to consumers as well.

“Moreover, the limited modeling and testing does not take into consideration the wide range of equipment that you are considering regulating — from small residential window air conditioners to 50-ton units used on large buildings. In the last few years, field testing has been done on less than 12 residential units, none until most recently placed in Texas.”

Reduces efficiency

ARI said that the proposed requirement would waste energy by coating the coils, thereby reducing the efficiency of the units. The institute estimated that the coating would increase the cost of a central air conditioner for the average residence by $1,000, and for larger businesses by many thousands of dollars.

The TNRCC’s proposal also raises substantial concerns about the capacity of the coating on the external heat exchanger to reduce ground-level ozone. It raises additional concerns about service life of the material and the likelihood that this material will flake off into the soil and groundwater. And, “it is fundamentally unfair to impose an ozone requirement on a product that is not a source of ozone,” states ARI.

The U.S. Department of Energy has expressed concern to the EPA, that “It does appear the coating has some negative impact on the efficiency of an air conditioning system. To the extent efficiency is reduced, the efficiency impact of requiring more electrical generation could offset the environmental benefit from ozone conversion. We believe more data should be obtained on the efficiency impact of this coating before any action requiring its use is taken.”

ARI is concerned that efficiency losses from the catalytic coating could cause air conditioners to fall below federal energy efficiency standards, which would violate the federal Energy Policy and Conservation Act (EPCA). Power plants would be forced to generate more energy in a state where air conditioning is a lifesaver in 100°-plus weather, and brownouts can be a significant problem.

In addition, due to the higher cost of the new air conditioners, some consumers would choose to keep older and less efficient air conditioners in operation. lN