April 10, 2008: ACCA Responds to California Energy Efficiency Plan
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.
ACCA’s key recommendations included:
• Encouraging the utilities to immediately create an HVAC industry task group to assist in planning and implementation.
• Urging adoption of national “Quality Installation” and “Quality Maintenance” standards.
• Asking 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.
• Informing the utilities that their proposal for an “Internet-based tracking system that tracks the status of equipment from the initial sale ... to the final quality check” is impractical and not cost-effective.
• Commenting that any new requirements must have consistent, fair, and strong enforcement provisions in place. Otherwise good businesses will be placed at a competitive disadvantage against shirkers.
• Pointing out that the plan did not address a fundamental issue, which is the need to strengthen California’s contractor licensing laws to require continuing education and license reviews.
• And, noting that, while the plan did not specifically state a desire for the state to develop its own standards and equipment specifications, it alludes to it, and ACCA 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 a variety of 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).
ACCA’s complete response may be read online at www.acca.org/testimony/. The original proposal from the California Investor Owned Utilities is available at www.californiaenergyefficiency.com.
Publication date: 04/07/2008