It seems the sun, the moon, the planets, and even a few stars are in perfect alignment. This could be one of those wondrously rare occasions when the Environmental Protection Agency (EPA) has exercised an uncommon degree of common sense.

The EPA has started revisions to the Energy Star specifications for residential central air conditioners and heat pumps. The changes proposed on Jan. 28, 2005, represent a major shift in the program.

In addition to energy efficiency criteria for equipment, the EPA is proposing "quality" installation requirements including proper sizing of equipment, matched assembly of split systems, and independent verification that airflow and refrigerant charge meet the manufacturer's specifications.

The issue is currently being studied in committee, with these changes slated to be effective in 2007. (The fact that it is being studied "in committee" virtually ensures that it won't come out the way it went in.)

One issue of great concern to the industry, according to the Air-Conditioning and Refrigeration Institute (ARI), involves proposed changes to the way the Energy Star label can be used to promote high-efficiency equipment.

Specifically, manufacturers would no longer be allowed to label equipment as it leaves the factory. Labeling would instead occur once installation is completed and the airflow and refrigerant charge have been independently verified.

Of course, this would present some marketing disadvantages to ARI member companies, which would no longer be able to promote Energy Star compliance - compliance would be in the hands of the installing HVAC contractors.

Here's where the EPA's common sense becomes obvious. Contractors have always had the ability to alter, adjust, or ensure the integrity of a manufacturer's unit. It has always been in a contractor's hands to create an air distribution system, properly balanced, properly zoned, with proper humidification control that works with the manufacturer's box.

The air conditioner or heat pump box is just one component of the system - a system that only you, Mr. Contractor, can bring to completion. My faith in Uncle Sam has been reinvigorated. Yes, EPA, you've got the right idea.

An Energy Star label on a box does not guarantee that occupants are receiving the benefits of high efficiency. Sure, it's rated at the factory as perhaps a 13- or 18-SEER unit. However, if the installing contractor does not at the very least give air distribution and refrigerant charge due diligence, that efficiency label means absolutely nothing.

One Label Or Two?

According to sources at ARI, the most likely outcome of the EPA's effort will be the creation of a two-stage labeling program: perhaps an "Energy Star Manufactured" label will take the place of the current label, and another label could be created for installation.

Granted, there will certainly be bumps in the road as the EPA attempts to implement such a plan. Who will verify installations? The installing contractor?

Of course not. The fox can't watch the henhouse.

At least hundreds, if not thousands, of third parties will have to be certified as capable of verifying installations. That's no easy task to find, train, or fund the work of such a verification body.

If this all sounds like more government regulatory activity and intervention, perhaps you are right. First, the efficiency level was mandated. Now, a proposal to verify the actual delivery of the efficiency is being discussed. What's next, a mandate for comfort?

For decades there have been low barriers to entry into the HVAC contracting trade; it may be time for a change. Thank goodness the EPA has at least recognized the importance of the contractor's role toward ensuring the efficiency of a manufactured unit.

Mike Murphy is editor-in-chief. He can be reached at 248-244-6446, 248-244-2905 (fax), or

Publication date: 05/02/2005