AHRI stated that either a test procedure or energy conservation standard rulemaking for these products is unnecessary, duplicative, and will not achieve any additional energy savings for the nation because systems that include these components are already subject to DOE energy conservation standards. “Regulation of commercial and industrial fans and blowers is impractical because the standalone performance is different from the fan or blower performance within a system,” noted AHRI. In addition, said the association, DOE’s intentions are based on analyses conducted on outdated data.

AHRI commented, “From our review of this notice of proposed determination of coverage, it is clear that DOE has underestimated the energy savings that are achieved through the major energy building codes in the U.S. and through existing DOE energy conservation standards for commercial equipment.” Therefore, the association sees “no compelling reasons why DOE should venture into regulating these products.”

Publication date:08/08/2011