Regionalization, part deux

Well folks, it appears that the U.S Environmental Protection Agency is at it again. Presently, the EPA is receiving comments from throughout the industry regarding the EPA Energy Star Program Requirements Product Specification for Furnaces Eligibility Criteria 3.0: Draft 2.

In this draft numerous items are covered, including the proposal of regional standards for residential furnaces. Included in that draft is the proposal that ENERGY STAR qualification would be determined by intended distribution and sales. As part of that program, the EPA would divide the U.S. and Canada up into three regions (Canada; U.S. North; and U.S. South, respectively). According to the draft proposed, equipment sold in each of those regions would have to meet specific criteria for that region in order to receive the ENERGY STAR rating.

For example, under the current draft proposal, a gas furnace in the U.S. North region (Alaska, Colorado, Connecticut, Idaho, Illinois, Indiana, Iowa, Kansas, Maine, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New York, North Dakota, Ohio, Oregon, Pennsylvania, Rhode Island, South Dakota, Utah, Vermont, Washington, West Virginia, Wisconsin and Wyoming) would have to have an AFUE of ≥92%; AECR (kWh) is yet to be determined; and air leakage (Qleak) of 2%. Conversely, that same furnace in the U.S. South region (Alabama, American Samoa, Arizona, Arkansas, California, Delaware, District of Columbia, Florida, Georgia, Guam, Hawaii, Kentucky, Louisiana, Maryland, Mississippi, Nevada, New Mexico, North Carolina, Oklahoma, Puerto Rico, South Carolina, Tennessee, Texas and Virginia) would have to have an AFUE of ≥90% (the other specs would be the same). In Canada, the AFUE required would be ≥94%. Oil furnaces in both the U.S. and Canada would require an AFUE of ≥85%.

And if that wasn't confusing enough, the EPA draft also states that "to earn the ENERGY STAR, models offered in multiple configurations (i.e., upflow, downflow, horizontal, lowboy) shall meet the regional ENERGY STAR levels presented [as listed in the previous paragraph] for all configurations they are offered in. For example, if a model is intended to be sold in the U.S. North region and is offered in upflow, downflow, and horizontal configurations, then the model shall meet the U.S. North region ENERGY STAR levels as tested in all three configurations. Manufacturers cannot claim that a model meets ENERGY STAR U.S. North when installed in the downflow configuration only. Similarly, a model cannot be qualified across two different regions depending on configuration. For example, if sold in Canada all configurations shall meet the Canadian requirements [as listed in the previous paragraph] to bear the ENERGY STAR. Models may qualify for labeling in every region for which all offered configurations meet the requirements of that region. For instance, models qualified for labeling in Canada may also be labeled everywhere in the U.S."

Got that?

If you answered no, you're not the only one. And the production nightmare for manufacturers hasn't been lost on them. Heating, Airconditioning and Refrigeration Distributors International (HARDI), the American Gas Association (AGA) and others have all submitted comments to the EPA stating that the idea of regional standards is a bad one. Jonathan Melchi, HARDI Manager of Government Affairs (and one of the contributors to RSES Journal's monthly Capitol Climate column), noted in his letter to the EPA's Abigail Daken: "If a consumer in Northern Kentucky purchased an ENERGY STAR qualifying furnace in Kentucky and subsequently moves five miles into Ohio and purchases the same product; are they to believe that same model somehow became less efficient in their new residence?"

It will be very interesting to see how this plays out over the next few months. The EPA originally hoped to have a standard in place by Sept. 1, 2011. Given the amount of feedback, and the fact that a whole new version of the draft was written up, that timetable seems unlikely. But one thing is for sure...more standards are on the way. Those in the industry need to pay attention, let their voices be heard when they can, and make sure those they elect understand their needs and concerns. After all, elections are only 22 months away...