No Time for Input

In October 2013, the DOE published a notice of proposed rulemaking (NOPR) for residential furnace fan energy conservation standards. However, the deadline to submit comments on the energy conservation standards was Dec. 24, 2013 — more than a week before the testing standards were finalized.

“It’s hard to assess the standard when you don’t know how they’re going to do the test procedures themselves,” explained Charlie McCrudden, senior vice president of government relations at Air Conditioning Contractors of America (ACCA). “There was a public meeting on the energy conservation standard on Dec. 9, 2013, and several times it was brought up that it’s hard for industry members to comment on the proposed standard when we don’t even know what the test procedures are. The DOE said they’d have the testing standard in time for interested parties to submit comments, but they didn’t.” After some outcry from concerned HVAC leaders, the DOE pushed the comment deadline back 30 days to Jan. 23, 2014.

“In a way, they jumped ahead of themselves,” said Jon Melchi, director of government affairs at Heating, Air-conditioning, and Refrigeration Distributors International (HARDI). “This delay has everything to do with them not wanting to be liable because they hadn’t approved the testing procedures, which was a concern for a lot of manufacturers.”

“They did this because they realized the predicament we were all in,” McCrudden said. “It’s really hard to comment on Step 2 when Step 1 is not done.”

But, even with the extension, McCrudden said the holidays had an impact on the industry’s ability to submit comments by the Jan. 23 deadline. “I think more than 30 days would’ve been helpful,” he said. “I’m of the opinion that more time means better comments. This is the first time we’ve considered standards for furnace fans, and I think the industry would’ve appreciated more time to review the test procedure final rule and then apply that to the comments on the energy use standards.”

A ‘Disturbing Trend’

Even though the DOE was willing to extend the deadline to submit comments on the residential furnace fan energy conservation standards, Melchi said the DOE’s eagerness to regulate the energy efficiency of components like furnace fans is worrisome, to say the least.

“It’s a disturbing trend that the DOE is attempting to regulate components of a system when our industry and consumers are used to a system-based performance rating,” Melchi said. “If a piece of equipment is helping a system reach a rating that meets the minimum efficiency standards set forth by the federal government, it’s hard for us to see why you’d have to go to a component-by-component way of rating, but that appears to be what’s happening.”

One of the problems with regulating components like furnace fans, McCrudden explained, is that the way a piece of equipment behaves by itself often does not dictate how it will perform as part of a system, especially since there are often many other variables at play that can affect overall energy efficiency.

“It’s hard to generalize and capture all of the potential issues or operating conditions for furnace fans,” McCrudden said. “That’s another part of the frustration. These aren’t running in a laboratory atmosphere — they’re running out in the field. The manufacturers don’t like the fact that they’re testing and rating a component to a whole product, which also has a testing and rating applied to it. Before, the use of the energy by the fan was sort of captured by the overall rating and testing of the appliance itself, but now you’ve got essentially two different metrics being used.”

Melchi said HARDI is also “wary of the DOE’s increased willingness to regulate on a component-by-component basis for products that have long been classified and certified as a system.” Ultimately, anything that constricts consumer choice and increases cost to the consumer is “not what we consider ideal,” he added. “It’s not something that HARDI is supportive of. It could lead to more repair-versus-replace situations. It negates much of the energy savings that these regulations are supposed to promote.”

While improving energy efficiency is important, there are better ways to do it. “It compounds over time,” McCrudden said. “It sounds trite, but it’s more regulation, it’s more red tape, and it’s more hoops the entire industry has to jump through.”

It Affects Everyone

Even though HVAC manufacturers will be most affected by the furnace fan testing procedures and energy conservation standards, Air-Conditioning, Heating & Refrigeration Institute (AHRI) declined to comment on the fan test procedures or energy conservation standards while rulemaking was ongoing. However, a spokesperson for the organization said the institute submitted comments on the residential furnace fan energy conservation standards prior to the published deadline.

“It’s likely to cause the manufacturers a considerable amount of time, money, and effort to comply, which will be passed down the distribution chain ultimately to the homeowner,” Melchi said. “A homeowner is buying a piece of equipment based on the performance of a system. If that system is getting 14 SEER or 90 percent AFUE, what difference does it make what motor is in there?”

“Contractors should pay attention to this rulemaking because it is going to impact the cost of a new furnace and the cost of replacement fans,” McCrudden added. “Be ready for the price of replacement parts to increase and, potentially, the price for new equipment to go up.”

While it may be too late for interested parties to be able to influence the energy conservation standards for residential furnace fans, McCrudden said it is more important than ever that all industry parties keep an eye on what the DOE is doing.

“Time and time again, we’ve seen there’s not a lot of grounding in reality when the DOE makes certain assumptions or determinations during these rulemakings. There’s an assumption of how much a contractor makes on a replacement job, but I think those numbers don’t always reflect reality, and as you work all of those improper assumptions through the formula, we see where there’s a justification for an increased standard that I don’t think is based on reality.”

“There’s limited rationale behind it,” Melchi agreed. “The DOE seems to hold the theory that because it can do something, it should, even if its rationale for doing so is flimsy and industry has operated under a system with effective third-party testing for a substantial period of time, which is proven to protect consumers and businesses alike. This regulation appears to restrict consumer choice, predetermine winners and losers, and not take into account the system performance, manufacturers’ best judgment, and consumers’ best judgment.”

SIDEBAR: What Products Are Affected?

According to the notice of proposed rulemaking (NOPR) published Oct. 25, 2013, in the Federal Register, the U.S. Department of Energy (DOE) must prescribe energy conservation standards for various consumer products and certain commercial and industrial equipment, including residential furnace fans, pursuant to the Energy Policy and Conservation Act of 1975 (EPCA), as amended.

EPCA requires DOE to determine whether such standards would be technologically feasible and economically justified, and would save a significant amount of energy.

For this rulemaking, DOE proposes to differentiate between product classes based on internal structure and application-specific design differences that impact furnace fan energy consumption. DOE proposes the following product classes for this rulemaking:

• Nonweatherized, Noncondensing Gas Furnace Fan (NWG–NC);

• Nonweatherized, Condensing Gas Furnace Fan (NWG–C);

• Weatherized, Noncondensing Gas Furnace Fan (WG–NC);

• Nonweatherized, Noncondensing Oil Furnace Fan (NWO–NC);

• Nonweatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB);

• Manufactured Home, Nonweatherized, Noncondensing Gas Furnace Fan (MH–NWG–NC);

• Manufactured Home, Nonweatherized, Condensing Gas Furnace Fan (MH–NWG–C);

• Manufactured Home, Electric Furnace/Modular Blower Fan (MH–EF/MB);

• Manufactured Home, Weatherized Gas Furnace Fan (MH–WG); and

• Manufactured Home, Nonweatherized Oil Furnace Fan (MH–NWO).

Each product class title includes descriptors that indicate the application-specific design and internal structure of its included products. Weatherized and nonweatherized are descriptors that indicate whether the HVAC product is installed outdoors or indoors, respectively. Weatherized products also include an internal evaporator coil, while nonweatherized products are not shipped with an evaporator coil but may be designed to be paired with one.

Condensing refers to the presence of a secondary, condensing heat exchanger in addition to the primary combustion heat exchanger in certain furnaces. The presence of an evaporator coil or secondary heat exchanger significantly impacts the internal structure of an HVAC product, and in turn, the energy performance of the furnace fan integrated in that HVAC product. Manufactured-home products meet certain design requirements that allow them to be installed in manufactured homes (e.g., a more compact cabinet size). Descriptors for gas, oil, or electric indicate the type of fuel that the HVAC product uses to produce heat, which determines the type and geometry of the primary heat exchanger used in the HVAC product.

Through the process, the DOE is seeking comments on a number of issues related to furnace fans including whether it should include a rated airflow capacity range or a rated horsepower range to help define test procedure applicability; input on the use of annual electricity energy consumption ratings for regulating furnace fans (along with any other relevant efficiency descriptors); comments on the relationship between speed control setting, or speed tap, and use in heating, cooling, or circulation functions of active mode furnace fan operation; and more.

The DOE selected a five-year compliance date for the new standards after publication of the final rule. For more information on the residential furnace fan energy conservation standards, visit http://bit.ly/FurnaceFanStandards.

Publication date: 2/10/2014 

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