AHRI Comments to DOE on Energy Efficiency Enforcement Jun 30, 2010

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The Air-Conditioning, Heating, and Refrigeration Institute recently submitted comments to the U.S. Department of Energy (DOE) regarding proposed revisions to DOE energy efficiency enforcement regulations. AHRI supported continuation of third-party submission of certification reports, recommended that DOE focus enforcement on products for which there are no third-party Voluntary Industry Certification Program (VICP), and recommended that recertification only be required when energy efficiency or energy consumption of a basic model increases or decreases by more than 5%.

AHRI said in its comments that it opposed DOE's proposal for a new annual certification reporting requirement on grounds that it would be redundant. AHRI already submits regular certification reports to DOE; an annual report would contain no new or different information.

AHRI also opposed a proposed requirement for a unified model numbering system. AHRI believes such a requirement is unwarranted and outside of DOE's authority.

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